Transfer Pricing Treatment of Intangibles: Issues and Developments

20 May 2019
Dr Emmanuel Llinares and Ralph Meghames

The WU Transfer Pricing Center at the Institute for Austrian and International Tax Law in Vienna has published a book based on the outcomes of the presentations and discussions held during the 2018 WU Transfer Pricing Symposium.

NERA Managing Director Dr Emmanuel Llinares and Principal Ralph Meghames contributed a chapter on “Pricing and Valuing Intangibles.” The authors provide a case study illustrating a situation where a willing seller and a willing acquirer are considering entering into a transaction that involves the transfer of hard-to-value intangibles. They discuss the limits of the DCF approach in such circumstances and describe how alternative valuation models based on Monte Carlo simulations and Real options can be applied.

Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions can be purchased online here