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

ktMINE Data

ktMINE is the most comprehensive repository of intangibles data, including:

• Trademark Assignments

• Connections

• Corporate Trees

Geographic Coverage

Company Coverage

Industry Coverage

Worldwide

Millions of Public and Private Companies

All Industries

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

Recent Transfer Pricing Posts

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What Our Transfer Pricing Customers Say

“As a global provider of transfer pricing services, we maintain high standards for research tools. ktMINE’s royalty rate and agreements applications, as well as their hands-on customer support and research services, exceed these standards. ktMINE’s professionals have extensive industry and transfer pricing knowledge, as such, ktMINE is not only our data provider, but a trusted partner as well.”

-Partner, RSM

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.

Common Questions

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.

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