Articles by Kris (Kestutis) Rudzika

Kris (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.

Service fees: how to calculate arm’s length pricing

For transfer pricing consultants, the ability to identify and apply the appropriate transfer pricing method is essential to ensure accurate and compliant results – and it’s no different when it comes to calculating arm’s length pricing for intra-group service fees. We’ve put together this brief overview to break down the different methods and the scenarios in which to use them.

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What is the ISO 10668 standard on brand valuation?

In 2010, the International Organization for Standardization (ISO) released ISO 10668: Brand Valuation to help businesses measure the value of their brands consistently and accurately. In this article, we provide an overview of ISO 10668 and its guidance on brand valuation.

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What is the royalty relief methodology (relief from royalty method)?

The royalty relief methodology (also called the relief from royalty method or royalty savings method) is one of the methods that can be used to value intellectual property assets. In this article, we discuss the royalty relief method in more detail and explain how it is applied.

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An overview of the IRS transfer pricing documentation FAQs

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.

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How to select comparables for your transfer pricing analysis

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.

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How to choose a transfer pricing method

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.

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What is the 25% rule in intellectual property valuation?

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.

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What is an arm’s length transaction in transfer pricing?

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.

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Transfer Pricing Calculation: Traditional transactional methods vs transactional profit methods

Transfer Pricing Calculation: Traditional transactional methods vs transactional profit methods

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?

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What is a royalty payment?

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.

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