The principles set out in paragraphs 2.12, 3.58 and 3.59 regarding the use of more than one transfer pricing method apply to matters involving the transfer...

Valuation 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...

A further consideration in evaluating the reliability of projections involves whether the intangibles and the products or services to which they relate have an established track...

When applying valuation techniques, including valuation techniques based on projected cash flows, it is important to recognise that the estimates of value based on such techniques...

The use of transfer pricing methods that seek to estimate the value of intangibles based on the cost of intangible development is generally discouraged. There rarely...

In 2005 Amazon US entered into a cost sharing arrangement (CSA) with its Luxembourg subsidiary, Amazon Lux. Pursuant to entering the CSA, Amazon US granted Amazon Lux the right to use certain pre-existing...