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OECD to issue review of hindsight

November 17, 2010

Sophie Ashley - TPW

The OECD has sent a questionnaire to all member countries asking them how they deal with the issue of hindsight when forecasting the profits arising from intangibles.

“The OECD has identified the use, in transfer pricing matters and, in particular, in comparability analyses, of post-transaction and post-filing data, as a topic where there is insufficient common understanding,” said Caroline Silberztein, head of the transfer pricing unit at the OECD.

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