Transfer Pricing
Definition
The pricing of transactions between related entities within a multinational group, including the licensing of intellectual property, provision of services, and intercompany loans. Transfer pricing for intangibles — particularly IP licences between affiliated entities — is subject to the OECD arm's-length principle and is a major area of international tax scrutiny. Defensible IP transfer pricing requires robust intangible asset valuation and functional analysis documentation.
Related Terms
Related FAQ
What is the tax treatment of intangible assets and amortisation?
Under UK tax law, amortisation of certain intangible assets is tax-deductible; goodwill is not. Acquired intangibles (IP, customer contracts) typically qualify; internally developed intangibles must meet strict criteria.
Read full answer →What is transfer pricing and how does it affect intangible assets?
Transfer pricing requires related entities to charge market prices for transactions (including intangible asset licences) — mispricing is a red flag for HMRC and can trigger audits and penalties.
Read full answer →Can Opagio guarantee HMRC acceptance?
No. HMRC valuations require a qualified independent valuer and are assessed on the specific facts of each case. Opagio provides a defensible starting point but cannot guarantee regulatory acceptance.
Read full answer →Put this knowledge to work
Use Opagio's free tools to measure and grow the intangible assets that drive your business value.