Commentary

B4.144 Transfer pricing—intangible items: hard to value intangibles

Business tax
Business tax | Commentary

B4.144 Transfer pricing—intangible items: hard to value intangibles

Business tax | Commentary

B4.144 Transfer pricing—intangible items: hard to value intangibles

The BEPS project Action 8 specifically considered hard-to-value intangibles (HTVI) and section D.4 of Chapter VI of the OECD Guidelines1 addresses hard-to-value intangibles. This report mandated follow-up work relating to BEPS Action 8 and so, on 21 June 2018, the OECD Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles2 was published, which is formally incorporated into the OECD Guidelines as an annex to Chapter VI.

The OECD Guidelines acknowledge that tax administrations are likely to find it difficult to establish what factors are relevant when pricing transactions involving HTVIs and are therefore highly dependant on the insights and information provided by the taxpayer. As

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