Transfer Pricing & BEPS
Intercompany Movement of Intangibles
Implication: Ignoring this information can leave a professional unprepared, open to litigation and unable to appropriately document the ownership of a company’s intangibles.
Royalty Rates & Market Rates
Issue: Under recent case law and the Base Erosion and Profit Shifting (BEPS) Guidelines, the Comparable Uncontrolled Transaction (CUT) / Comparable Uncontrolled Pricing (CUP) method remains the preferred approach to benchmark transactions.
Solution: ktMINE offers millions of data points to assess the availability of comparable transactions to support intercompany analyses.
Independent Party Transaction Structures
Solution: ktMINE provides over a hundred thousand independent party deal structures for supporting transfer pricing analyses.
Implication: Inadequately reviewing independent party transactions can leave tax positions vulnerable to audits.
- Determining the arm’s length pricing for comparable transactions
- Evaluating factors of comparability
- Providing evidence for how independent parties would structure transactions involving intangibles
- Inventorying intangibles under analysis
- Providing a starting point in determining economic ownership
Global regulations are changing, and the way Transfer Pricing professionals go about their benchmarking analyses is changing right along with them. Gone are the days where guesswork, intuition and a small sampling of royalty rates is sufficient when conducting transfer pricing research. Ensuring transfer pricing compliance means having more data and the documentation to back it up.
ktMINE collects, organizes, and links intangible datasets, saving consultants valuable time and money. With ktMINE, easily gain insight into the intangibles of a company, relevant independent party transaction structures and comparable rates, all while creating the necessary documentation to defend your analyses.
Where do you get your data?
Through a proprietary process, ktMINE gathers innovation and intangible asset data from publicly available sources, such as the Securities and Exchange Commission, USPTO, and hundreds of news sources. Our mission is to find, analyze, and add any public document with viable innovation and intangible asset information into our database while making the search and review process for this information fast and accurate.
Are license agreements the only transactions you have?
No, we have various other forms of transactions such as: Supply, Distribution, Sales Agent, Contract Manufacturing, R&D Services, License of Intangibles, Financial Services, Administrative Services, Toll Manufacturing, Commission Agent and more.
Do you have international data?
A recent poll of our database showed over 75% of the data is exploited outside the U.S.
How is ktMINE adapting to the post BEPS landscape?
Fortunately, ktMINE was originally built with transfer pricing compliance in mind and has been anticipating a change like this for a few years. We have stayed ahead of the curve by allowing you access to both summaries, full text, and redacted agreements in order to appease the new call to validate your intercompany transactions.
How do I access the database?
ktMINE offers flexible access options to our transfer pricing data, such as day passes or customized subscriptions. Contact a representative to learn the best option for you.
What are my access options?
Access is annual subscription based. Customized application packages are available for full firms to individuals. Contact us for pricing and package options.
Do you provide transfer pricing research assistance?
Yes! Once you have subscribed you will be paired with a ktMINE customer success specialist. This will be your point person for any issues and help you may need. The ktMINE customer support line is also available at support@ktMINE or (312) 253-0926. We are more than happy to help you create a solid research strategy.
Request More Information