The Increasing Importance of Intangible Assets and the Rise of Profit Split Methods

One of the proposed changes in the 2009 edition of the OECD Guidelines is the new emphasis on the profit split method, which is to be used in those cases where there is insufficient data available to apply the traditional transaction methods. The present article considers this method, including its strengths and weaknesses, its application to locally developed intangibles, both from a general and a Mexican perspective. This article also reflects on relevant experiences with the Mexican tax authorities.