Corporate Reputation as an Intangible Asset for Transfer Pricing Purposes

This article defines corporate reputation as the strategic integration of ESG principles (environmental, social and governance) into the business model of a multinational group and examines its potential treatment as an intangible under the OECD Transfer Pricing Guidelines. On the basis of this definition, it analyses the legal characterization and the potential intra-group economic valuation of corporate reputation. The study incorporates a detailed functional analysis under different organizational structures (centralized and decentralized), identifies compensation mechanisms (such as royalties or profit split), and considers alternative approaches to its characterization (such as an intra-group service, a shareholder activity or an implicit guarantee). The proposal offers an innovative doctrinal contribution on a concept not expressly regulated, yet increasingly relevant in the context of contemporary international taxation.