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Structuring a License System

In: Intangibles in the World of Transfer Pricing

Author

Listed:
  • Tim Eggebrecht

    (Deloitte)

  • Markus Kircher

    (Deloitte)

  • Julia Kaiser

    (Deloitte)

Abstract

This chapter provides an overview of how a license model can be determined in line with the arm’s length principle. For this purpose, the parameters that need to be considered when structuring a license system are presented. The overview in this chapter includes fixed and flexible license schemes. Regarding flexible license schemes, the possible license bases and rates are discussed. To determine license rates, the respective transfer pricing methods are examined, with a focus on the external CUP approach. Finally, empirical observations on license arrangements between third parties are presented, including insights from a database analysis and from license contracts analyzed in recent license rate benchmark studies.

Suggested Citation

  • Tim Eggebrecht & Markus Kircher & Julia Kaiser, 2021. "Structuring a License System," Springer Books, in: Björn Heidecke & Marc C. Hübscher & Richard Schmidtke & Martin Schmitt (ed.), Intangibles in the World of Transfer Pricing, edition 1, pages 181-197, Springer.
    • Handle: RePEc:spr:sprchp:978-3-319-73332-6_10
    DOI: 10.1007/978-3-319-73332-6_10
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