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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