A Practical Solution for Hard-to-Value Intangibles

15 May 2019
Dr Yves Hervé and Philip de Homont

In their latest article for the International Tax Review, NERA Managing Director Dr. Yves Hervé and Associate Director Philip de Homont provide a practical approach for handling hard-to-value intangibles (HTVI) in the context of the OECD’s new transfer pricing (TP) guidelines.

The key point of the guidance is that the transfer of intangibles within a multinational group will often have to be revalued years after the original transfer based on new data. The authors use a case study to demonstrate the methods NERA has successfully deployed to consider the specific risks related to the development of HTVI and the benefits of careful planning and analysis.