Hard-to-Value Intangibles and the Pricing of Uncertainty

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.