ECONOMICS

Detailed explanation-1: -Intangible assets are assets that do not have a physical or financial embodiment. Termed ‘intellectual assets’ in previous OECD work, intangible assets have also been referred to as knowledge assets or intellectual capital. Much of the focus on intangibles has been on R&D, key personnel and software.

Detailed explanation-2: -The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle", which represents the international consensus on the valuation, for income tax purposes, of cross-border transactions between associated enterprises.

Detailed explanation-3: -Methods acknowledge by the OECD The five methods approved by the OECD are the comparable uncontrolled price (CUP) method, resale price method (RPM), cost plus method (CPM), transactional net margin method (TNMM) and the transactional profit split method (TPSM).

Detailed explanation-4: -HTVI guidance HTVI are defined as intangibles or rights in intangibles for which, at the time of the transaction, no reliable comparables existed, and projections of future cash flows expected to be derived from the transferred intangible or assumptions used in valuing the intangibles were highly uncertain.