Articles by Kris (Kestutis) Rudzika

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.

RoyaltyRange director Kris Rudzika

New US transfer pricing Directives: selecting the best method

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…

Read more
DEMPE explained

DEMPE explained

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…

Read more
Five new transfer pricing Directives are released in the US

Five new transfer pricing Directives are released in the US

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…

Read more
DEMPE: six steps for analyzing transactions involving intangibles

DEMPE: six steps for analyzing transactions involving intangibles

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…

Read more
Royalty rate benchmarking

Royalty rate benchmarking

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?…

Read more
What is functional analysis?

What is functional analysis?

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…

Read more
DEMPE functions

DEMPE functions

Under the arm‘s length principle, each member of the multinational enterprise group should receive arm‘s length compensation for the functions it performs…

Read more
Service agreement data

Service agreement data

RoyaltyRange has launched a new Service fee database and our clients can now access the quality service agreement data. The new Service fee database provides detailed data on the most recent agreements involving various types of services…

Read more
Database subscription plans

Database subscription plans

RoyaltyRange is happy to provide our customers with a wide range of subscription options for our intellectual property database. Take your pick from 6 different plans to get the optimal subscription package for your needs…

Read more
Tax treaty history in the making

Tax treaty history in the making

On Wednesday June 7th, 2017, ministers and officials from 68 nations met in Paris to sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (“Multilateral Instrument” or “MLI”)…

Read more