Glossary
Transfer pricing
The rules governing the prices charged between entities under common control, requiring them to reflect what unrelated parties would agree.
Wherever a group has more than one entity, transfer pricing applies. For digital-asset groups it typically arises on development services charged between an operating company and a foundation, on mining rewards allocated across borders, and on treasury functions.
There is no crypto-specific guidance, so the general framework for intangibles applies — which turns on who develops, enhances, maintains, protects and exploits the intellectual property, rather than who legally owns it.
Where this comes up
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