RoyaltyStat Blog

Residual Profit Split is an Avoidable Cul-de-Sac

Posted by Ednaldo Silva on Feb 21, 2017 4:20:07 PM

The claim that it is impossible to find comparable royalty rates and that from the start we should use the residual profit split method for high-value intangibles needs revisiting. This claim is made prima facie without regard for the license agreements available in curated databases such as RoyaltyStat, which as of today contains over 17,875 unique and unredacted license agreements. Also, adopting the residual profit split method, when separate tested party methods such as the TNMM could suffice, creates unwarranted costs and audit management challenges for both the taxpayer and the tax administration.

Forecasting Profit Margin Under CWI

Posted by Ednaldo Silva on Nov 4, 2016 9:33:34 AM

We can consider a first-order autoregressive (AR(1)) model to determine an arm’s length profit margin of a “tested party” subject to transfer pricing audit compliance:

Properties of the AR(1) Model of the Profit Margin

Posted by Ednaldo Silva on Oct 31, 2016 10:13:44 AM

It’s useful to study the mean and variance of the first-order autoregressive model (AR(1)), which is postulated as univariate:

Determining Arm's Length Profit Margins Using the AR(1) Model

Posted by Ednaldo Silva on Oct 31, 2016 7:16:59 AM

We can determine an arm's length profit margin (expressed as operating profit divided by net sales) of a controlled taxpayer (“tested party”) by using a first-order autoregressive model, which we can show (like any stable first-order difference equation) to be equivalent to a range of comparable “routine” profit margins plus a weighted random error time series.

Operating Profit Margins Don't Obey the Normal Distribution

Posted by Ednaldo Silva on Oct 21, 2016 7:13:23 AM

The operating profit margin (measured after depreciation and amortization (OMAD)) of 23,151 companies listed in many countries, reflecting fiscal year-end 2015 accounting results, departs from the usually presumed normal distribution. In this sample, OMAD gets a better fit using the Gamma distribution.

Royalty Rates for Medical Devices

Posted by Ednaldo Silva on Sep 27, 2016 11:42:30 AM

Naive analysts use the normal (Gauss-Laplace) distribution to compute the mean and standard deviation, or quartiles, without verifying if the data are abiding. Double fault is committed when they propose a “broad and unconvincing” range of data, such as the interquartile range (IQR), which may become useless to determine arm’s length (or reasonable) royalty rates. In practice, the interquartile range of royalty rates is used to help settle licensing disputes in tax or intellectual property valuation. 

Double Log Operating Profit Margin

Posted by Ednaldo Silva on Sep 2, 2016 12:22:00 PM

Computation of an arm's length operating profit margin is not as easy as it seems. As an example, we consider the directly proportional profit model postulated by the OECD Transfer Pricing Guidelines and the more likely power function that we may encounter when we analyze actual comparable data including small and large enterprises. In cases when the selected comparables include small, medium and large uncontrolled enterprises, an arm's length operating profit margin is more likely to be reliably measured by a double log or power function. The operating profit margin is defined as operating profits (before or after depreciation and amortization) divided by sales revenue.

RoyaltyStat Keyword Search

Posted by Małgorzata Brożyna on Jul 7, 2016 6:34:17 AM

Many search queries entered in the RoyaltyStat search form contain only one keyword or a short phrase such as injection, inject*, mold*, form*, utility*, wireless equipment. One keyword or one phrase search queries are combined with the use of simple operators AND, OR, AND NOT to join the initial keywords.  E.g. inject* OR mold* OR form* in a single query. Initially, users enter a prototypical word of a category or, simply, a word or phrase they know. They don’t develop their search strategies further and don't appear to use our search guide. This behavior is known as a paradox of the active user.

Profit Margin with Heterogeneous Variance

Posted by Ednaldo Silva on Jun 23, 2016 8:24:25 AM

In transfer pricing, we may encounter a situation in which the statistical residuals among the selected comparables do not have a common variance. This phenomenon is called heteroskedascity. To correct this problem, we can transform or deflate the relevant variables and measure them as ratios. E.g., suppose that we have comparable company coordinated pairs of data on sales (S) and “net” (operating) profits (P), and their bivariate scatter diagram suggests a linear relationship:

Gross Profit Methods are Unreliable

Posted by Ednaldo Silva on Jun 14, 2016 5:59:10 AM

If an enterprise makes or buys goods to sell, the cost of goods sold (COGS) can be deducted from net receipts. However, to determine COGS, the inventory at the beginning and end of each tax year must be valued. Consider the symbols: