High local marketing spend needs a clearer brand royalty story

The main issueBrand value and local market-building should tell one consistent story.

Separate ordinary local marketing from activities that may enhance brand value.

Explain who controls strategy, bears risk and owns resulting marketing intangibles.

Review the brand rights received under the licence and any local restrictions.

Keep the royalty benchmark aligned with the wider functional analysis.

TPRoyalty note

This is a concise research note, not a substitute for the facts and legal or transfer-pricing requirements of a particular case.

Issue themes also discussed in VSTN Consultancy's public note on transfer-pricing issues for royalty transactions. Open public reference ↗