Does Cambridge Partners perform intellectual property appraisals for transfer pricing strategies?
Yes. Cambridge Partners performs transfer pricing studies for purposes of international transfer pricing and state and local tax transfer pricing strategies. We understand that in a transaction consummated between parties, the arm’s-length principle is imperative. The arm’s length principal states that such transactions should be carried out under terms and at a price that could have been reasonably expected under similar circumstances (e.g., similar product or service, market, credit terms, reliability and supply, and other pertinent circumstances) if the parties had been dealing at arm’s-length. For cross border and local transactions, we utilize IRC Section 482 as guidance in determining arm’s-length rates. The regulations in IRC Section 482 (§482) provide several basic methods for establishing royalty rates. These methods are the: Comparable Uncontrolled Transactions Method (“CUT Method”); Comparable Profits Method; Profit Split Method; and Other, unspecified methods.
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