H.T.V.I. has been singled out as being one of the leading causes of base erosion and profit shifting (“B.E.P.S.”). Michael Peggs, co-head of the transfer pricing practice of Ruchelman P.L.L.C., makes a valiant attempt at explaining a method to value intangible property that is “hard to value” while being compliant with the B.E.P.S. Action Plan. He suggests a combination of common sense and reliable data.