Our intervention involves demonstrating the fair character of the transfer price, especially with regard to brand and patent royalty fees paid. We also opinionate on the interest rate charged for intragroup loans.


Our approach for analyzing transfer prices is grounded in the recommendations published by the OECD, including:

  • A functional analysis on the role of each company involved, the risk they assume, and the assets they use
  • Implement methods prescribed by the OECD, particularly the comparables and the profit-split methods

To estimate the royalty rate for a brand, a patent, or even a specific know-how, we favor the comparables method. Alternatively, we estimate the royalty rate by determining the Key Success Factors (KSF), the profit margins, and the role of the targeted intangible asset in relation to other assets to supplement our comparables method, or to replace it if it can’t be applied.

With regard to the interest rates charged for intragroup loans, our analysis is based on market data, the borrower’s credit risk, and the loan covenants.

Our Work

  • Publish recommendations for determining a royalty rate or other types of transfer prices
  • Assist in case of litigation

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