Competencies, Competence and the Arm’s Length Principle

Journal
Collier, R.S.; Dykes, I.F.
International; OECD
Bulletin for International Taxation 2023 (Volume 77), No. 12
Price USD 45

This article is concerned with competencies and competency assets, a form of intangible asset. The discussion deals primarily with the nature of competency assets, and why they are important in the context of the current income allocation rules, despite being barely recognized by the OECD Transfer Pricing Guidelines.