We can provide you with an independent view of arm’s length prices companies should pay for your marketing services, brands and other IP. Using detailed market research and financial methodologies which have been used and approved by tax authorities including, the IRS, HMRC, SARS, ATO, we can provide you with commercially-based analysis to support your intra-company profit splits.
Unilever - Tax & Transfer Pricing Analysis
Unilever is an Anglo-Dutch multinational consumer goods company. Brand Finance was appointed by Unilever Indonesia (ULI) to provide an analysis of the economic contribution of certain brands manufactured, distributed and marketed by ULI and, in addition, to assess the arm’s length royalty rates that may be deemed appropriate for the licensing of these brands to ULI. This opinion was supported by evidence based on two methodologies, namely the ‘Brand Contribution Method’ and the ‘Economic Use Method’. Subsequently, appropriate pre-tax royalty rates for the subject brands were determined.
Theodore Kletnick, International Trial Attorney, IRS
“Brand Finance has assisted the Internal Revenue Service by providing expert witness valuations of trademarks and other intangible assets for several major Section 482 transfer pricing cases. In addition, in connection with these cases, Brand Finance has provided an opinion on related issues including the determination of appropriate royalty rates and the significance of license agreement terms, including exclusivity vs. non-exclusivity. I have found Brand Finance to be skilled, effective and thoroughly professional in their approach and fully satisfied with their work, which has enabled us to achieve very favourable settlements in very difficult cases. In the future, I would use them for similar projects.”