Tag: Pricing controlled transactions involving intangibles

TPG2022 Chapter VI paragraph 6.108

However, the principles of Chapters I – III can sometimes be difficult to apply to controlled transactions involving intangibles. Intangibles may have special characteristics that complicate the search for comparables, and in some cases make pricing difficult to determine at the time of the transaction. Further, for wholly legitimate business reasons, due to the relationship between them, associated enterprises might sometimes structure a transaction involving intangibles in a manner that independent enterprises would not contemplate. See paragraph 1.11. The use or transfer of intangibles may raise challenging issues regarding comparability, selection of transfer pricing methods, and determination of arm’s length conditions for transactions. This Section D provides supplemental guidance for use in applying the principles of Chapters I – III to determine arm’s length conditions for controlled transactions involving intangibles ...

TPG2017 Chapter VI paragraph 6.108

However, the principles of Chapters I – III can sometimes be difficult to apply to controlled transactions involving intangibles. Intangibles may have special characteristics that complicate the search for comparables, and in some cases make pricing difficult to determine at the time of the transaction. Further, for wholly legitimate business reasons, due to the relationship between them, associated enterprises might sometimes structure a transaction involving intangibles in a manner that independent enterprises would not contemplate. See paragraph 1.11. The use or transfer of intangibles may raise challenging issues regarding comparability, selection of transfer pricing methods, and determination of arm’s length conditions for transactions. This Section D provides supplemental guidance for use in applying the principles of Chapters I – III to determine arm’s length conditions for controlled transactions involving intangibles ...