The main issueUse time as evidence, not as an automatic rejection rule.
01
Check the effective period and relevant market conditions.
02
Review whether the licensed intangible and commercial model changed.
03
Document why age matters in this case rather than applying a blanket cut-off.
04
Consider adjustments or sensitivity analysis where appropriate.
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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