Examination of the Transfer Pricing challenges of Hard to Value Intangibles (HITV).

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dc.contributor.authorIsau Olatunji Ahmed
dc.date.accessioned2026-05-14T10:32:53Z
dc.date.available2026-05-14T10:32:53Z
dc.date.issued2021
dc.description.abstractThe Arm's Length Principle (ALP) is the cornerstone of the current transfer pricing regime. The application of the ALP is predicated on using the price charged in transactions between independent entities in an open market to determine or benchmark the appropriate transfer price to be charged in transactions between associated entities within a Multinational Corporation (MNC) Group. At the time when the ALP was adopted, transactions in tangible items were prevalent and there were comparative market prices to determine the appropriate transfer price. The ALP was therefore considered as the best possible means to ensure that profits of associated entities derived from cross-border transactions are allocated in a way that is fair between the MNCs and the different tax jurisdictions in which they are doing business. However, advancements in technology gave rise to new business models that shifted transactions from the traditional tangible items to intangible items. These intangible items are unique items in the sense that they are hard to value due to the absence of comparative market prices to determine the transfer price. This constitutes a practical challenge to the application of the ALP which can create opportunities for tax avoidance. The objective of this article is to examine the nature of Hard to Value Intangible and its challenges to the application of the ALP. The article will also examine the recommendations proposed by the Organisation for Economic Cooperation and Development to overcome this challenge. The article examined the transfer pricing treatment of intangibles in Nigeria.
dc.identifier.citationIfe Juris Review, Journal of Contemporary Legal and Allied Issues, 1: 91-104
dc.identifier.issn0794-1048
dc.identifier.urihttps://kwasuspace.kwasu.edu.ng/handle/123456789/7144
dc.language.isoen
dc.publisherDepartment of Jurisprudence and Private Law, Obafemi Awolowo University, Ile Ife.
dc.titleExamination of the Transfer Pricing challenges of Hard to Value Intangibles (HITV).
dc.typeArticle
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