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Intangibles & financing

Where the largest adjustments come from. Value follows functions, assets, and risks — not legal ownership of an intangible or the label on a funding instrument.

Transactional profit split method

6 min

A method that divides the combined profit from a controlled transaction between the parties on an economically valid basis.

DEMPE

6 min

The framework allocating intangible returns to the entities that perform and control development, enhancement, maintenance, protection and exploitation functions.

Hard-to-value intangibles (HTVI)

5 min

Intangibles transferred between related parties for which no reliable comparables exist and projections at transfer are highly uncertain.

Intra-group financing

6 min

The pricing and characterisation of loans, guarantees, cash pooling and captive insurance between associated enterprises.

Business restructuring

6 min

The cross-border reallocation of functions, assets or risks between associated enterprises, and the compensation, if any, due for it.

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iVC Transfer Pricing Glossary (visit iVC Consulting)

A working reference for transfer pricing, grounded in the OECD Transfer Pricing Guidelines and labelled by source status so you always know what is authority and what is interpretation.

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Source policy

Every claim carries a label: primary source, secondary source, or our interpretation. Nothing here is tax advice for a specific fact pattern.

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