Comparability of intangibles


‘Comparability, and the possibility of making comparability adjustments, is especially important in considering potentially comparable intangibles and related royalty rates drawn from commercial databases or proprietary compilations of publicly available licence or similar agreements. <…> In particular, it is important to assess whether publicly available data drawn from commercial databases and proprietary compilation is sufficiently detailed to permit an evaluation of the specific features of intangibles that may be important in conducting a comparability analysis. <…>’1

Sufficiently Detailed Data

Each licence agreement report in the RoyaltyRange database contains all the necessary comparability factors to be in compliance with the recommendations under the final Action 8 report on Transfer ‎Pricing Aspects of Intangibles, released by the Organization for Economic Co-operation and Development (OECD) pursuant to the Action Plan on Base Erosion and Profit Shifting (BEPS) published on 5th of October of 2015. These comparability factors include a detailed functional analysis of:

  • Risks;
  • Costs;
  • Assets;
  • Functions.

This was achieved by taking into account OECD Guidance when it was in its draft form and compiling the RoyaltyRange database based on the forthcoming requirements. Our deep understanding of OECD practices and years of development have produced a tool that will benefit your projects and enable you to be compliant with ever-increasing requirements. Click here for more details on BEPS and RoyaltyRange.

1 OECD BEPS: Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 – 2015 Final Reports

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