The main issueShow why the right remains worth paying for.
01

Identify whether technology, know-how or brand rights remain active and valuable.

02

Document material updates or continuing support where those facts exist.

03

Avoid assuming that a recurring invoice proves recurring value.

04

Link the royalty term to the contractual and commercial reality.

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 ↗

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