Transfer Pricing & BEPS
Stronger, More Defensible Data — In Less Time
Leading tax authorities, corporations, law firms and consultants need access to reliable information to support and review independent party transaction structures.
ktMINE enables professionals to:
- Determine economic ownership by tracking intercompany movement of intangibles
- Identify comparable royalty rates & market rates
- Document independent party deal structures
Without ktMINE, professionals risk:
- Being caught under-prepared during audit and litigation
- Reducing the reliability of royalty rate analyses
- Failing to defend the structure of transactions
Intercompany Movement of Intangibles
Issue: Tax auditors monitor the intercompany, cross-border movement of intangibles to flag potential transfer pricing compliance issues.
Solution: ktMINE tracks and reports the cross-border movement of intangibles for all companies.
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.
Implication: Failing to search for comparable royalty rates or market rates can negatively impact the reliability of transfer pricing analyses and cause an increase in potential tax adjustments.
Independent Party Transaction Structures
Issue: As outlined in the BEPS Guidelines, it is no longer sufficient to only benchmark the actual price of a transaction. Practitioners must also research the structure of comparable independent party transactions.
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.
Use Cases
- 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
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Market Environment
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.
