A critical transfer pricing issue in all countries, and for all types of planning, is the definition of “intangibles.” It is often the case that the allocation of income is proportional to the ownership or development of intangible property. The Organisation for Economic Co-operation and Development (OECD) is, appropriately, vitally concerned with the inclusiveness of the concept of “intangibles” for transfer pricing purposes. The current discussion draft is interesting and raises many questions.
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