The aim of the publication is to help taxpayers improve the quality of their transfer pricing documentation so that 1) they avoid penalties; 2) there is a chance of issues being deselected early; and 3) the process is more efficient and cost-effective for taxpayers and examiners.
Articles by Kris (Kestutis) Rudzika
Kris (Kestutis) Rudzika
Kris is Managing Partner at RoyaltyRange. He has extensive experience in transfer pricing and specializes in post-BEPS transfer pricing analyses, including DEMPE analyses for intangibles. Previously, he was Transfer Pricing Director at EY Belgium. He has an advanced diploma in international taxation from the Chartered Institute of Taxation (CIOT) in the UK.
Because of the complex nature of intellectual property valuation, it can be difficult to find reliable comparables data that meets the strict comparability criteria required for certain transfer pricing methods. This article explains how you can get started with your search.
There are a number of transfer pricing methods you can use to determine arm’s length prices for controlled transactions between associated entities. Due to the complex nature of intellectual property valuation and licensing, there is no straightforward answer to which method is most appropriate.
In intellectual property valuation, the 25% rule is a rule of thumb that can be used to work out a fair royalty rate to charge in a licensing agreement for intellectual property assets.
When your company is made up of multiple legal entities, those entities often transfer goods, services and intellectual property between each other. If this is the case with your organization, you need to make sure that those transactions happen at arm’s length.
Traditional transactional methods and transactional profit methods are the two main types of method you can use when carrying out a transfer pricing calculation. But which type should you use for your analysis? What are the differences between them?
If you are entering into a license agreement – whether as a licensor or a licensee – you need to understand what a royalty payment is. Royalty payments are a basic component of any licensing deal.
When you draft license or franchise agreements, negotiate royalty rates, set transfer prices or value intellectual property, analyzing third-party royalty rates helps you determine a fair royalty fee, value or arm’s length rate for transfer pricing purposes.
Are you wondering how to value IP? Perhaps you are looking to buy, sell or license IP, or you need to know the value of your business’s IP for a merger or acquisition.