Hard-to-Value Intangibles and the Pricing of Uncertainty

Abstract

This article provides an overview of the development of chapter VI of the OECD Guidelines with respect to the specific addition of hard-to-value intangible (HTVI) as a new concept in the OECD’s transfer pricing guidance. Furthermore, it presents an approach to taking uncertainty into account when valuing HTVIs at best knowledge at the time such a transaction is entered into.