Topic collection
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 minA method that divides the combined profit from a controlled transaction between the parties on an economically valid basis.
DEMPE
6 minThe framework allocating intangible returns to the entities that perform and control development, enhancement, maintenance, protection and exploitation functions.
Hard-to-value intangibles (HTVI)
5 minIntangibles transferred between related parties for which no reliable comparables exist and projections at transfer are highly uncertain.
Intra-group financing
6 minThe pricing and characterisation of loans, guarantees, cash pooling and captive insurance between associated enterprises.
Business restructuring
6 minThe cross-border reallocation of functions, assets or risks between associated enterprises, and the compensation, if any, due for it.
Book a TP Health Check
Unsure how your transfer pricing would hold up?
A fixed-scope review of your intercompany pricing, documentation and audit exposure — scoped to your jurisdictions, delivered as a written risk memo. First response within one business day.
