Taxpayers and practitioners should, at minimum, review market transactions to understand how independent parties structure licensing deals. If the tested transaction does not follow suit, one should also be prepared to discuss why, and the impact on arm’s length pricing.
Action 8 under OECD BEPS plan, found in the most recent update of the Guidance on Transfer Aspects of Intangibles, guides taxpayers and practitioners to consider the conditions that would be agreed upon between independent parties.  Learn More.
With ktMINE License Agreements, you have access to over 100,000 licensing transactions sourced from the public domain. Reviewing the brief summaries, and full text of the agreements will allow you to answer two important questions:
- How would independent parties structure an intangibles transaction given the tested transaction’s facts and circumstances?
- What price would be agreed upon given this structure?
Contact us today for access.
 See Action 8 ¶¶ 6.137, 6.183, 6.184, 6.185, 6.3, 6.6, and 6.52