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RoyaltyRange director Kestutis Rudzika


Kris (Kestutis) Rudzika

Kris (Kestutis) has extensive experience in transfer pricing and specializes in operational transfer pricing, DEMPE analysis and intangibles. Previously, he was a Transfer Pricing Director at EY Belgium. He has an advanced diploma in international taxation from the Chartered Institute of Taxation in the UK. Kris is a lawyer and holds LL.M. degree. In addition, he completed financial analysis and blockchain strategy programmes at London Business School and Oxford University.

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Per Møller


Per is the Member of the Board and Strategy advisor at RoyaltyRange. Strong technical expertise and decades of experience drive his vision of future of tax. Per has previously served as the CEO of EY (Ernst & Young) in Denmark and other management positions.


Laurynas Riauba

Chief Technology Officer

Laurynas is a CTO at RoyaltyRange. Laurynas holds a PhD in Quantum Chemistry and MSc in Computer Science. Before joining RoyaltyRange he worked as CTO at 100+ employee applications and platforms engineering company which serves financial institutions and fintech clients. He is the leader to further accelerate RoyaltyRange’s strategy in the big data segment. He advances the databases and their ecosystem together with customers and partners.

Reima Linnanvirta


Reima Linnanvirta


Reima is the Chairman of the Board at RoyaltyRange. He is a board professional and investor in multiple international technology companies, especially in business-to-business software-as-a-service growth companies. Before focusing on private equity and board work, Reima acquired extensive expertise in tax, transfer pricing, and transactions, e.g. as a co-founder of Alder & Sound, where he was responsible for building the tax technology business, and from EY Finland.


Carlos Perez Gomez


Carlos leads RoyaltyRange growth in LATAM region. He is a transfer pricing expert that served as the Head of Transfer Pricing Taxation at the Mexican Central Tax Administration (SAT) and participated as delegate of the OECD’s Working Party No. 6 on the Taxation of Multinational Enterprises. Carlos now participates in the private sector, including transfer pricing training for governments along with regional organizations and NGO’s, and is a member of the United Nations Subcommittee on Transfer Pricing.


Solomon Choge

Head of Sales

Solomon is Head of Sales. Previously, he worked with the Thomson Reuters and Bureau van Dijk. He is specialist with a demonstrated history of working in the information services industry. Skilled in Transfer Pricing and International Tax.

RoyaltyRange manager Justinas Laniauskas


Justin Laniauskas

Senior Manager, New York

Justin is a Senior Manager at RoyaltyRange. Before joining company’s US office, he represented RoyaltyRange at events and meetings in Italy and Switzerland. He is actively involved in the development and quality maintenance of company’s loan interest rates database products. He has a cum laude Master’s degree in finance, and is working towards a Chartered Financial Analyst (CFA) certification.

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RoylatyRange director Asta Rudzikiene


Asta Rudzikiene

President - U.S.

Asta is a President at RoyaltyRange, Inc. (US). She has extensive experience in legal, tax and financial transactions. She is a lawyer and, before joining RoyaltyRange, worked at the notary office and a major bank for a number of years.

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RoyaltyRange manager Lukas Blaciunas


Lukas Balciunas

Senior Manager Europe, former manager for Italy

Lukas is a Senior Manager at RoyaltyRange. He holds a Master’s degree in European law from Radboud University (the Netherlands). Having worked as a researcher with other library-as-a-service platforms, Lukas has already built a reputation for providing high-quality data-driven solutions for clients.

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Anna Vadeike

Senior Manager for Eastern, Central Europe and CIS

Anna is a Senior Manager at the RoyaltyRange London office. She holds a Master’s degree in international and European Union law, and has focused her academic interests on legal aspects of transfer pricing. Anna leads the loan department, and is in charge of compiling and analyzing data on loan transactions. Anna also plays a key role in developing the company’s client portfolio in Central and Eastern Europe.

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RoylatyRange client support team leader Greta Eberson


Greta Eberson

Customer Support Team Lead

Greta is a Senior Consultant and Support Team Lead at RoyaltyRange. She ensures that our customer service is of the highest standard in terms of efficiency and quality, and that our clients are satisfied with the services we provide.

RoyaltyRange senior consultant Edita Aliukaite


Edita Aliukaite

Research Lead

Edita is a Senior Consultant and Research Team Lead. She is primarily responsible for performing one-off searches and ensuring that the results our clients receive are highly relevant to their needs. Prior to being appointed as Senior Consultant, she was part of our service fees department, performing data screening and compilation projects for service fees transactions.

Photo of RoylatyRange employee Auguste Norkeviciute


Auguste Norkeviciute

Analytics Lead

Auguste is an Analytics Lead at RoyaltyRange. She holds a Master’s degree in law. Auguste focuses on the search and analysis of royalty rate agreements. She makes sure our data is high-quality, compliant with the requirements of the OECD BEPS initiative, and relevant for a wide range of purposes and requirements.

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Just want to say thank you, I think you have a great service and appreciate your consistent and high-quality deliverables. Your support is always appreciated!Sean McNama, Transfer Pricing, RSM Canada

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OECD definition of royalties


According to Article 12 of the OECD Model Convention with Respect to Taxes on Income and on Capital, the term ‘royalties’ refers to ‘payments’ of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work including cinematograph films, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience’. As stated in the Glossary of Industrial Organisation Economincs and Industrial Law (term 116), published by the OECD, ‘Copyright, trademark and patent holders may license others to use or produce the good, usually in return for a fixed payment and a royalty rates’.

According to the Commentaries on the Articles of the Model Tax Convention (Commentary on Article 12, Paragraph 2 (point 8)), ‘the definition applies to payments for the use of, or the entitlement to use, rights of the kind mentioned, whether or not they have been, or are required to be, registered in a public register. The definition covers both payments made under a licence and compensation which a person would be obliged to pay for fraudulently copying or infringing the right’.

There is an ongoing debate about whether the definition of royalties should be an open or a closed definition. The current approach used in the Model Tax Convention suggests that the closed definition is appropriate; however, some people argue that a new sentence should be included in the OECD definition that states that other types of rights or assets similar to those expressly mentioned may also bring about royalties.

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Royalty rates data


How can one get the royalty rates data? As indicated below, a source for such arm’s length royalty rates could be found in commercial databases. Royalty rates for various types of intangibles, e.g. trademarks, trade names, patents, know-how and others can be found there.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (Chapter III, Section A.4.3.1, paragraph 3.30) identifies that there are various sources of information that can be used to identify potential external comparables. A common source of information is commercial databases that can be practical and cost-effective way of identifying external comparables and may provide the most reliable source of information. Revision of the Special Considerations for intangibles in Chapter VI of the OECD Transfer Pricing Guidelines and Related Provisions (Chapter IV, Section D.1., paragraph 103) further states that ‘Comparability, and the possibility of making comparability adjustments, is especially important in considering potentially comparable intangibles and related royalty rates drawn from commercial data bases’.

RoyaltyRange royalty rates database provides reliable and detailed data on the comparable licence agreements involving intellectual property and royalty rates. Our proprietary royalty rates database contains manually gathered and analysed data on the most recent licensing transactions and royalty rates in various industrial sectors. Our data reports contain more than 50 standartised comparability factors on royalty rates and other terms of the licence and only unredacted agreements (i.e., licences where royalty rates are disclosed) containing royalty rates expressed in percentages are included in the database.

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Alternative definition of royalties


Following a simpler definition, royalties are payments made by one party, the licensee (the user of intangibles), to another party, the licensor (the owner of intangibles), for the use of intangibles owned by the licensor. Royalties are often expressed as a percentage of the revenues obtained using the owner’s property; however, they can be also expressed in other terms (including a fixed value), depending on the specific characteristics of the licence agreement.

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What are intangibles


In order to better understand what royalties are, it is important to define the term ‘intangibles’. According to the definition given in paragraph 6.6 of Section A of the final report of Action 8 published by OECD on 5th October of 2015 under the Base Erosion and Profit Shifting (BEPS) initiative: ‘Intangible is intended to address something which is not a physical asset or a financial asset, which is capable of being owned or controlled for use in commercial activities, and whose use or transfer would be compensated had it occurred in a transaction between independent parties in comparable circumstances’.

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Economic and legal ownership of intangibles


This definition also brings up an extremely important question regarding ownership of intangibles and of what ‘being owned or controlled’ actually means. There is an ongoing debate about the distinction between economic and legal ownership of intangibles. As paragraph 6.32 of Section B of the final report of Action 8 published by OECD on 5th October 2015 under the BEPS initiative notes: ‘Although the legal owner of an intangible may receive the proceeds from exploitation of the intangible, other members of the legal owner’s multinational enterprise (MNE) group may have performed functions, used assets, or assumed risks that are expected to contribute to the value of the intangible’.

In this regard, it is considered that the companies of the group that perform such functions, use such assets, and assume such risks must be compensated for their contributions under the arm’s length principle. Consequently, it is derived that ‘the ultimate allocation of the returns derived by the MNE group from the exploitation of intangibles, and the ultimate allocation of costs and other burdens related to intangibles among members of the MNE group, is accomplished by compensating members of the MNE group for functions performed, assets used, and risks assumed in the development, enhancement, maintenance, protection and exploitation of intangibles’.

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