Intangibles play an important role in the processes of many business enterprises. They facilitate value creation and enhance the profitability of businesses that deploy them. They are also valuable assets that can be traded in themselves, although their appropriate values are often difficult to...

The article argues that the BEPS project has made only minimal progress in its work on the transfer pricing for intangibles, despite the prominence of the issue. More specifically, it achieved none but increased confusion and incoherence in the context of the specific rules for CCAs

OECD Transfer Pricing Guidelines (TPG), after 2015 BEPS documents, enforce the rule according to which the intangible funder is not allowed to gain intangibles' revenues when lacking ability to control the project development performed by other group companies.OECD rule has a primary anti-abuse...