Articles by Kris (Kestutis) Rudzika

This page explains how to calculate arm’s length royalty rates and how to use reliable comparables data to strengthen your negotiating position or to ensure your transfer pricing compliance.

The CUP method is a traditional transaction method. Traditional transaction methods are considered the most direct way of determining whether prices and conditions between associated enterprises are at arm’s length.

The Actions 8–10 report by the Organisation for Economic Co-operation and Development (OECD), released in October 2015, states that the arm’s length principle requires that all members of the group receive appropriate compensation for any functions they perform, assets they use…

In the 2017 edition of the Transfer Pricing Guidelines, the Organisation for Economic Co-operation and Development (OECD) outlines six steps for analyzing transactions involving intangibles. Step 1 is to “Identify the intangibles used or transferred in the transaction with specificity and the specific, economically significant risks

Many professionals find the concept of blockchain difficult to explain, and it is even more difficult for people outside the field to understand it.

Essentially, this is an evolution of several other technologies from the past…

Five new transfer pricing Directives were released by the Internal Revenue Service (IRS) Large Business and International (LB&I) Division on January 12^th, 2018. They aim to reduce the volume of open transfer pricing cases and limit disputes…

The introduction of the concept of development, enhancement, maintenance, protection and exploitation of intangibles (DEMPE) has resulted in significant changes in how multinational enterprises (MNEs) implement the arm’s length principle…

On January 12^th, 2018, the Internal Revenue Service (IRS) Large Business and International (LB&I) Division released a set of five Directives, addressing how it approaches examination when auditing a taxpayer’s transfer pricing practices…

Section 6.34 of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 (published by the OECD) outlines six steps for MNEs to follow when analyzing transactions involving intangibles…

What is the market royalty rate for licensing a clothing brand? Is a 5% royalty rate for licensing your technology too low in comparison with the rates applied by third parties? Did your client set a market royalty rate when granting a licence to its subsidiary?…