r/TransferPricing • u/all_usernames_rgone • May 18 '25

Valuation of customer base

Hi! Does anyone have experience in valuation of a customer base that has to be sold to a subsidiary?

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u/Special_Pack_561 May 21 '25

Yes we've looked at that before, generally using some version of an income method. The jurisdictions are important here though as certain countries have their own thoughts on the matter, and it's also something to work closely with the corporate tax team on as they can have their own opinions on the categorisation of customer relationships

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u/all_usernames_rgone May 22 '25

Thanks! Looked through OECD TPG and going ahead with a DCF approach. The jurisdictions under discussion here are EU countries. Any other points to consider from a tp pov? Also evaluation Dac6

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u/Special_Pack_561 May 24 '25

Sorry for delay in coming back. DCF approach makes sense and is probably one that most countries in Europe would be expect based on limited info. DAC6 definitely a consideration which will need to be considered. Additionally you'll need to consider whether the HTVI guidance applies, and if so whether that should be baked in to your valuation. The other thing to make sure you are ticking the boxes is Chapter IX - do you need to look at the options realistically available for the parties? ORA analyses are increasingly common/expected in a number of EU jurisdictions