From Definition to DCF: A Practical Framework for the Valuation of Intangibles for Transfer Pricing Purposes
This article provides practical guidance for the transfer pricing valuation of intangible assets in technology-intensive companies. It addresses key challenges, including delineating technology- and marketing-related intellectual property (IP), mapping interdependencies and translating financial planning and analysis projections into IP-specific cash flows at an appropriate discount rate. The article emphasizes precise IP definition, strategic functional interviews, value-chain analysis and the careful determination of discount rates. By integrating financial, operational, transfer pricing and valuation perspectives within a granular operational transfer pricing framework, the approach enables defensible, economically grounded and forward-looking valuations of complex intangible portfolios.
Authors
- Yongchong Mao
Publication Details
- Journal
- International Transfer Pricing Journal
- Published
- 2026-04-30
- DOI
- https://doi.org/10.59403/2b5c9sz
- Primary Topic
- Intellectual Capital and Performance Analysis
- Type
- article
- Field-Weighted Citation Impact
- 0.00