Are Royalties Dutiable? A Tango between Transfer Pricing and Customs Valuation

Journal
Kuijper, S.; Long, Y. (Yi); Schippers, M.L.; Bongard, B. van den
International
International Transfer Pricing Journal 2023 (Volume 30), No. 6
Price USD 45

This article provides a theoretical framework on the interaction between transfer pricing and customs valuation with a specific focus on the treatment of royalties. In addition, the article provides the transfer pricing and customs analysis of a case study regarding the commonly seen structure of the fixed rate royalty and residual royalty model.