Moreover, it should also be noted that access to an assembled workforce with particular skills and experience may, in some circumstances, enhance the value of transferred intangibles or other assets, even where the employees making up the workforce are not transferred. Example 23 Â in Annex I to Chapter VI illustrates one fact pattern where the interaction between intangibles and access to an assembled workforce may be important in a transfer pricing analysis.
TPG2022 Chapter I paragraph 1.176
Category: D. Guidance for applying the arm’s length principle | Tag: Access to workforce in place, Enhancement of value, Workforce in place / Assembled workforce
« Prev |
Next » Related Guidelines
- TPG2022 Chapter VIII paragraph 8.27While all contributions should be measured at value (but see paragraph 8.28 below), it may be more administrable for taxpayers to pay current contributions at cost. This may be particularly relevant for development CCAs. If this approach is adopted, the pre-existing contributions should...