PwC’s comments on the Revised Discussion Draft on Transfer Pricing Aspects of Intangibles


In July 2013, the OECD released its Revised Discussion Draft on the Transfer Pricing Aspects of Intangibles. PwC immediately informed its network of what had changed compared to the prior Discussion Draft. Now we are also providing you with the more detailed comments we sent the OECD regarding their Revised Discussion Draft.

The following topics were touched upon:

  • Section A: Definition of Intangibles;
  • Section B: Emphasis on Functions versus Assets & Risks, and Recharacterization;
  • Section D: Valuation Techniques, Profit Split Method of Valuation, Valuation Techniques Where Valuation of Intangibles is Highly Uncertain and Location Savings.