Unexecuted template agreements cannot serve as CUP comparables, and routine business expenses including RSUs, IT support, and promotions are allowable.
Unexecuted template agreements cannot serve as CUP comparables, and routine business expenses including RSUs, IT support, and promotions are allowable. Issue Transfer Pricing of Royalty: Whether unexecuted template agreements can be applied under the CUP method to benchmark royalty payments, and whether purchase and royalty transactions can be aggregated under the Resale Price Method (RPM).… Read More »