Editing Transfer pricing (section)

===Intangible property issues===
Valuable intangible property tends to be unique.  Often there are no comparable items.  The value added by use of intangibles may be represented in prices of goods or services, or by payment of fees (royalties) for use of the intangible property.  Licensing of intangibles thus presents difficulties in identifying comparable items for testing.<ref>OECD Chapter VI, 26 CFR 1.482-4.</ref>  However, where the same property is licensed to independent parties, such license may provide comparable transactional prices.  The profit split method specifically attempts to take value of intangibles into account.