The highly anticipated Discussion Draft of Chapter VI of the OECD’s Transfer Pricing Guidelines and Related Provisions (the Intangibles chapter), clearly shows that the OECD has made significant progress since they kicked off the project in November 2010. Some of the highlights we discuss are the definitional aspects of intangibles, ownership and entitlement to premium returns, identifying transactions involving the use of transfer of intangibles and pricing the transaction.
Read the full report to find out what’s new in this draft and our observations.
