Study on the application of economic valuation techniques for determining transfer prices of cross border transactions between members of multinational enterprise groups in the EU : executive summary (EN)

This document provides a view on how valuation techniques can practically and most efficiently be used for transfer pricing purposes in the EU. The information to support the study was gathered through desk research and interviews with transfer pricing and corporate finance valuation specialists from all EU Member States and nine of the EU's main trade partners. The study investigates the differences between valuations for transfer pricing purposes and valuations for other purposes, and the state of play in terms of experience of the EU Member States and trade partners. This was conducted through four aspects: 1) a SWOT analysis of economic valuation techniques applied in the context of transfer pricing, 2) the practical application of these techniques in the EU Member States and trade partners, 3) the identification of potential legislative measures, and 4) capacity building approaches for tax administrations. The report concludes with considerations of potential policy actions that could offer helpful guidance to both tax administrations and taxpayers regarding the valuation of intangibles for transfer pricing purposes in the EU.