Tag Archive | transfer pricing

Africa: Status of Transfer Pricing in Africa (Part 1)

Status of transfer pricing in Africa (Part I) ENSafrica Celia Becker Status of transfer pricing in Africa (Part I) Tanzania publicly released its Transfer Pricing Regulations (the Tanzanian Regulations) in May 2014, joining the growing number of African jurisdictions whose transfer pricing regimes have progressed beyond broad general anti-avoidance provisions based on the arm’s length […]

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Posted in FP News, Transfer Pricing

Transfer Pricing: 25% rule of thumb not applicable to determining royalty rates

Transfer Pricing: 25% rule of thumb not applicable to determining royalty rates Attached please find a recent U.S. Court of Appeals for the Federal Circuit case (September 16, 2014 in VirnetX, Inc. v. Cisco Sys., Inc.) in which a U.S. court finds again the “25 percent rule of thumb” to determine royalty rates inadmissible: “[W]e […]

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Posted in Transfer Pricing