Is there anything specific regarding transfer pricing a startup company should pay attention to?

Intangibles can create a significant part of a company's value. Therefore the transfer pricing considerations for intangibles are often relevant. It is important to note that the intangibles to be considered for transfer pricing purposes are not always recognised as intangible assets for accounting purposes. Intangibles may be generated in research and development activities, production and manufacturing as well as in sales and marketing. Patents, trademarks, copyrights, business names, design rights, know-how and trade secrets are typical intangibles.