Miscellaneous 2022

Transfer pricing and intangibles - part 3: valuing intangibles for the purposes of Subdivision 815-B and the 2017 OECD Transfer pricing guidelines

Source: The Tax Specialist Journal Article

Published Date: 1 Jun 2022


Parts 1 and 2 of this article considered the analysis of intangibles under the transfer pricing rules in Subdiv 815-B of the Income Tax Assessment Act 1997 (Cth) and under the OECD's 2017 Transfer pricing guidelines for multinational enterprises and tax administrations (2017 OECD TP guidelines), respectively. Part 3 of this article considers how transfers of intangibles or rights in intangibles might be valued under the 2017 OECD TP guidelines, and compares this with how arm's length conditions are identified in Subdiv 815-B in relation to such transfers.

Sorry, this is subscriber only content.

To gain access to this material and much more - Subscribe Now.

(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).

Already a Subscriber? Login now

Already a Subscriber? Login now


The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))


The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.


Miscellaneous 2022

Share this page