The OECD Discussion Draft on Intangibles and the Myth of Unavailable Comparables

Authored by David R. Jarczyk, and Jeffrey Cozzo, this article argues that the Organization for Economic Cooperation and Development’s revised discussion draft on intangibles lacks guidance on the available market evidence to answer the central question of an arm’s length analysis: How would independent parties act given the tested transactions’ facts and circumstances?

Versions Published In:

  • October, 2013 Bloomberg BNA Transfer Pricing Report
  • November 2013 Bloomberg BNA Transfer Pricing International Journal

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About the author: ktMINE
ktMINE
Based in Chicago, IL, ktMINE collects, organizes, and connects transactional and IP data to help you quickly and confidently perform research. ktMINE then take that data and turn it into real, actionable insights. Because ktMINE believes that there’s a big difference between data and intelligence.