The main issueThe controlled agreement should be understood before searching for uncontrolled agreements.
01
Map licensed rights, territory, duration and restrictions.
02
Identify the payment base, timing and other consideration.
03
Compare contractual terms with actual functions and risks.
04
Explain material differences in the benchmarking file.
TPRoyalty note
This is a concise research note, not a substitute for the facts and legal or transfer-pricing requirements of a particular case.
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