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
Articles by Kestutis Rudzika
Kestutis Rudzika
Kestutis 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.
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…
Five new transfer pricing Directives were released by the Internal Revenue Service (IRS) Large Business and International (LB&I) Division on January 12th, 2018. They aim to reduce the volume of open transfer pricing cases and limit disputes…
DEMPE explained
March 2018
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 12th, 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…
Royalty rate benchmarking
October 2017
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?…
What is functional analysis?
October 2017
As the Organisation for Economic Co-operation and Development (OECD)’s 2017 edition of the Transfer Pricing Guidelines provides only a short explanation of what a functional analysis is, we thought we would explain it in more detail here…
DEMPE functional analysis
September 2017
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…
DEMPE functions
August 2017
Under the arm‘s length principle, each member of the multinational enterprise group should receive arm‘s length compensation for the functions it performs…