JTPF report valuation
Report on the Application of Economic Valuation Techniques (2017)
Category: Application of Economic Valuation Techniques within the EU (2016/2017), EU Transfer Pricing Reports | Tag: Accounting valuation, Bargaining power, Calculation of Discount Rates, CAPM, Cost approach, Discount rate, Discounted Cash Flow (DCF), Financial projections, Growth rates, Income based approach, Intangibles, Market approach, Relief from Royalty method, Sanity check, TAB, Tax effects, Two-sided method, Useful life, Valuation, Valuation techniques, WACC, WARA
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TPG2017 Chapter VI paragraph 6.172
It should be recognised in determining and evaluating discount rates that in some instances, particularly those associated with the valuation of intangibles still in development, intangibles...
TPG2017 Chapter VI paragraph 6.171There is no single measure for a discount rate that is appropriate for transfer pricing purposes in all instances. Neither taxpayers nor tax administrations should assume...
TPG2017 Chapter VI paragraph 6.170The discount rate or rates used in converting a stream of projected cash flows into a present value is a critical element of a valuation model....
TPG2017 Chapter VI paragraph 6.174Valuation techniques are often premised on the projection of cash flows derived from the exploitation of the intangible over the useful life of the intangible in...
TPG2017 Chapter VI paragraph 6.157Valuation techniques that estimate the discounted value of projected future cash flows derived from the exploitation of the transferred intangible or intangibles can be particularly useful...
TP case laws
US vs. Amazon, March 2017, US Tax Court