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.
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.
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.
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
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…
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…