INTM421110 | Transfer pricing: Methodologies: OECD Guidelines: Intangibles

The rules covered by this guidance page were subject to reform in Finance Bill 2025- 26. As such you may need to consider the draft guidance at INTM414000 from 1 January 2026.

For an introduction to intangibles, a summary of what the OECD Transfer Pricing Guidelines say about them, and consideration of their significance in relation to transfer pricing, please see the material at in the chapter at INTM440000, in particular:

INTM440110 Intangibles: what are intangibles?

INTM440130 Intangibles: fragmentation

INTM440180 Intangibles: royalties, treaties and TIOPA10/S132