A royalty benchmark does not prove need or benefit by itself

The main issueDefend both the transaction and the price.

Document the licensed technology, brand or know-how actually used.

Connect the payment to identifiable business benefits or access rights.

Keep evidence of updates, support, queries, training or other continuing value where relevant.

Treat benefit evidence and rate benchmarking as complementary workstreams.

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 ↗