The importance of intangibles in everyday economic life is steadily increasing. As a result, the complex issues of evaluation, identification and allocation of intangibles are increasingly becoming the focus of tax authorities and international organizations such as the OECD. In the course of this thesis, the fundamental transfer pricing issues of intangible assets will be explained in order to address the currently discussed special case of "hard-to-value intangibles". The reader will find a discussion of the concerns expressed, the recommended approach of the OECD-TPG and the Implementation-Guidelines of the BEPS Action 8 on "hard-to-value-intangibles", some criticisms of them as well as an example illustrating the topic further. Since documentation plays an important role, especially for intangibles, the documentation requirements, which are expanded by the Austrian Transfer Pricing Documentation Act, are reviewed with a focus on intangibles.