Valuations for Transfer Pricing of Intangibles: A Comparative Analysis of the Excess Earnings Method and Residual Profit Split

Abstract

With the increasing relevance of intangible assets in the process of value creation, the measurement of the portion of the firm profit attributable to such assets is becoming progressively more crucial. Absent any harmonization between the different underlying views of the firms, the comparison between the results obtained with different methods developed in a different context and for different purposes (accounting and tax), although sharing the same basic logic (residual approach), appears to be problematic.