Trends in transfer pricing of R&D and IP activities

Post-BEPS, post-pandemic corporate reorganization, whether it is driven by controversy risk mitigation or commercial necessity, often involves restructuring of intangibles and the associated R&D activities. The restructuring options and potential solutions have to be evaluated based on transfer pricing considerations in the OECD Transfer Pricing Guidelines and the interpretations that countries have adopted in respect of these guidelines. At the same time, we see an increase in tax audits and litigation related to transfer pricing and intangibles. Often these cases relate to royalty rates, cost sharing or intangibles being transferred within the group. Where are the stress points that often give rise to disputes? What are some of the strategies that multinational groups could consider in order to manage potential disputes? What is the anticipated impact of the OECD two-pillar solutions on the structuring of intangibles and R&D activities?


Topics Covered

Block 1: Trends in the Structuring of Intangibles and R&D Activities

  • Structuring of intangibles
  • Structuring of R&D activities

Block 2: Application of OECD Transfer Pricing Guidelines to the Structuring of Intangibles and R&D Activities

  • Potential areas of disputes
  • Some practical tips in controversy management and dispute resolution

Block 3: Recent Cases

  • Selected cases and what can be learned from them
  • Assessing the anticipated impact on multinational groups

Learning Objectives

After this webinar, the participants will be able to: 

  • Identify the areas in OECD Transfer Pricing Guidelines on intangibles that are most likely to be associated with cross-border disputes
  • Define the key challenges MNEs face in setting the arm’s length price for R&D activities and transactions involving the use or transfer of intangibles
  • Compare and contrast the latest policy and legislative developments on transfer pricing and intangibles
  • Assess the impact of the latest case law concerning transfer pricing of intangibles


To be determined

Field of study


Who should participate

In-house tax professionals and advisers looking to understand transfer pricing aspects of the structuring of intangibles and R&D activities within a multinational group - Legal professionals assessing the compliance risk associated with the application of Chapter VI of the OECD Transfer Pricing Guidelines, and how to comply with the associated rules and manage the potential controversy risk associated with these rules - Government officials engaging in the audit and enforcement of transfer pricing requirements in intra-group transactions involving intangibles and R&D activities

Course level and prerequisites

This is an intermediate-level webinar. Participants in this webinar are expected to have at least 3 to 5 years of experience in international tax and be familiar with the key concepts of international tax law.

Advance preparation

No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.

Interactive webinar – “Group Internet Based” (live webinar only)

During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions. Participants will also have access to the on-demand version for a further 12 months from the live date.

Date of live broadcast: 30 January 2024

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.

Continuing Professional Education

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Webinar registration details

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