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.