The OECD has identified transfer pricing issues pertaining to intangibles as a key area of concern to governments and taxpayers, due to insufficient international guidance in particular on the definition, identification and valuation of intangibles for transfer pricing purposes.
The OECD is now considering starting a new project on the Transfer Pricing Aspects of Intangibles which could result in a revision of Chapters VI and VIII of the TPG (which deal with intangibles) and is looking for comments on these issues.
Working Party No. 6 of the Committee on Fiscal Affairs is still at the stage of scoping such a possible new project and would welcome the views of interested parties on: what they see as the most significant issues encountered in practice in relation to the transfer pricing aspects of intangibles; what shortfalls, if any, they identify in the existing OECD guidance; what the areas are in which they believe the OECD could usefully do further work; and what they believe the format of the final output of the OECD work should be. Comments should be sent before 15 September 2010 in Word format to Jeffrey Owens, Director, CTPA (firstname.lastname@example.org).