Action 8 BEPS Guidance: Use of Valuation Techniques To Estimate Arm's-Length Prices in Intangibles Transfers

The authors discuss the revised OECD transfer pricing guidance following BEPS Action 8 (intangibles) specifically with respect to the use of valuation techniques as one of the OECD recognized methods or as a useful tool in estimating the arm’s-length price for the transfer of intangibles. In applying valuation techniques, it is important that the arm’s length principle is considered. In addition, the assumptions and valuation parameters used should be properly substantiated and documented.