Third-party franchise agreements can provide highly useful information for transfer pricing professionals analyzing franchise transactions involving intangibles.
Articles by Kris (Kestutis) Rudzika
Kris (Kestutis) Rudzika
Kris is Transfer Pricing Director and Tax Lawyer 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.
There are no typical technology licensing fees or patent licensing fees. Technology licensing agreements are complex and, as such, technology and patent licensing fees differ greatly.
License agreements and royalties for inventions are complicated, and broad royalty rates averages often overlook the nuances and complexities of individual licensing situations.
In this article, we explain how to determine royalty rates for pharma licensing deals using the market approach (using comparable pharmaceutical royalty rates to set your own).
How to set royalty rates in fashion
April 2019
A detailed explanation how to determine royalty rates in fashion and why high-quality comparables data is so important. You will find it useful if you need to set royalty rates for your products or analyze your current royalty rates to make sure they are at arm’s length for transfer pricing purposes.
How to set food royalty rates
April 2019
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.
DEMPE functional analysis
August 2018
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
So, what exactly is “Blockchain”?
July 2018
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…