Returns from intangible property accrue to the entities that perform the functions, contribute the assets and control the risks associated with its development, enhancement, maintenance, protection and exploitation. Legal ownership alone does not entitle an entity to the residual return — a principle tax authorities now apply with considerable confidence.
The service covers:
- DEMPE functional analysis, establishing which entity performs and controls each relevant function
- Characterisation and pricing of licensing arrangements, cost contribution arrangements and intangible transfers
- Royalty rate benchmarking using comparable licensing agreements
- Valuation support for intangible transfers
- Analysis of hard-to-value intangibles
- Interaction with the Cyprus IP Box regime, ensuring the transfer pricing position and the qualifying income calculation are mutually consistent
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