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.