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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…

Author: Kestutis Rudzika

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How royalties are calculated

How royalties are calculated

Royalty rates refer to payments that are made when a licensee uses a licensor’s intellectual property (IP), as per a license agreement between the two parties. As the Organisation for Economic Co-operation and Development (OECD) states…

Author: Lukas Balciunas

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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?…

Author: Kestutis Rudzika

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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…

Author: Kestutis Rudzika

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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…

Author: Kestutis Rudzika

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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…

Author: Kestutis Rudzika

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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…

Author: Kestutis Rudzika

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RoyaltyRange team

Our great customer support team moved to the new offices!

We have many priorities, but excellent customer service and support is always a top priority.
So, we feel proud and happy when…

Author: Greta Eberson

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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”)…

Author: Kestutis Rudzika

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How transfer pricing regulations are being enforced around the world

How transfer pricing regulations are being enforced around the world

Global transfer pricing regulations have undergone significant changes in recent years, as governments around the world have realized the importance of stopping multinational enterprises (MNEs) reduce tax through international profit shifting…

Author: Justinas Laniauskas

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