Transfer Pricing & BEPS

How to Navigate BEPS

By September 29, 2015August 8th, 2023No Comments

In light of the evolving Transfer Pricing landscape being caused by the BEPS project, there is uncertainty on how to validate your intercompany transactions structures.

ktMINE offers a solution that makes structuring intercompany transactions easier.

Imagine you need to structure an intercompany transaction between a US Based Insurance Company, called Insure Co USA, and their subsidiary in Canada, called Insure Canada Inc. In the transaction, the licensee Insure Canada Inc will be responsible for acquiring the regulatory registration to use the trademarks in the territory. Under BEPS, it may be important to confirm that other licensees in independent transactions would agree to similar transactions in case you get challenged.

By using the ktMINE Agreements App, users are able to find independent evidence that third parties would agree to these terms and use it to support intercompany transactions. Sometimes benchmarking a transaction requires going beyond the royalty rate information and that is where having access to over 100,000 agreements becomes important.

Using the ktMINE Agreements App to support this transaction is as simple as 1: Performing a Search, 2: Reviewing Results, and 3: Implement the Results. Let’s see the Agreements App in action:

1: Perform a Search:

For this search, let’s  begin by searching by a few different phrases that may be useful in finding section related to Regulatory Registrations. Users may add additional phrases and industries to find additional results.

Navigate BEPS 1

2: Reviewing Results

Next, let’s review the populated results along with the full text of agreements. With access to these agreements, you can now create defensible intercompany agreements that are supported by third party agreement evidence.

Navigate BEPS 2

3: Implement the Results

Now, you are able to support your intercompany transactions that are based on third party transaction evidence.