The OECD Intangibles Project and the Concept of “Intangible Related Return”

This article examines the OECD’s recent work regarding certain transfer pricing aspects of intangibles as reflected in BEPS Action Plan No. 8. In particular, the authors provide a description of the project, as well as the activities undertaken by Working Party No. 6 up to March 2014, describe the interim work performed by Working Party No. 6 in connection with the attribution of the “Intangible Related Return” to members of a multinational group and address comments on the “Intangible Related Return” concept received by Working Party No. 6 from business commentators.