Volume 39 (2011) / Issue 3

Andreas Oestreicher, 'Valuation Issues in Transfer Pricing of Intangibles: Comments on the Scoping of an OECD Project' (2011) 39 Intertax, Issue 3, pp. 126–131


After finalizing its revision of Chapters I and III of the Transfer Pricing Guidelines and adding a chapter on business restructurings last summer, in January 2011 the Organisation for Economic Co-operation and Development (OECD) embarked on a new project on the transfer pricing aspects of intangibles. Questions arising in this context cover a wide range of issues including, in particular, the methodologies and arameters used in valuation of such assets. Against this background, this article provides a brief summary of some fundamental valuation issues in transfer pricing of intangibles and looks at possible solutions. Corresponding guidance is based on relevant experience gathered when contributing to the discussion regarding transfer pricing aspects of valuing intangible assets that has been taking place in Germany over recent years.

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ISSN: 0165-2826
ID: TAXI2011012