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What happened at the OECD’s recent consultation on transfer pricing

Richard Collier and Aamer Rafiq, PwC

On 12 and 13 November the OECD held a consultation on transfer pricing. Broadcast online and open to members of the public it was attended by country tax authority delegates to the OECD Working Party No. 6 as well as representatives from interested business professional civil society and media groups globally ...

Intangibles

Further work needs to be done on the definition of intangibles. Specifically many delegates felt that intangibles should be limited to assets which are proprietary in nature i.e. with reference to rights which are protected by law or contract. The majority view was that goodwill should be taken into account when determining the arm’s length price of a business transfer but should not be considered an intangible in its own right. A large consensus of delegates agreed that the term ‘marketing intangibles’ is...

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