Service

Royalty, Services & Interest Rate Benchmarking

At AventaaGlobal, we deliver specialised benchmarking studies for royalty rates, intercompany service fees, and interest rates across India and global jurisdictions. We use a combination of jurisdiction-relevant databases, publicly available third-party agreements, and market data to establish arm’s length ranges for specific transaction types.

These studies support intercompany pricing decisions, transfer pricing positions, licensing and technology arrangements, valuation inputs, and commercial negotiations—while remaining defensible under a CUP-based approach where appropriate.

What We Cover

Royalty Benchmarking (Intangibles / Licences)

We benchmark royalty rates by identifying third-party licence agreements with comparable:

IP type and rights granted (use/exploit/sublicense)

territory, exclusivity, and term

industry and economic context

payment base (sales/revenue/units) and escalation clauses

Royalty benchmarking support with intangibles characterisation (DEMPE-aligned)

We strengthen comparability by mapping key IP characteristics and value drivers (including DEMPE-aligned considerations) to improve the selection and justification of comparable licence agreements.

Intercompany Services Benchmarking

We benchmark service fees by analysing third-party arrangements and market evidence, considering:

nature and scope of services and deliverables

pricing model (fixed, time-based, cost-based, etc.)

responsibility split, risk allocation, and service intensity

contract terms, duration, and renewal conditions

Service scope and pricing basis alignment

We help align the defined service scope and pricing basis with market evidence used in the benchmarking set, improving consistency and defensibility.

Intercompany Loans and Interest Rate Benchmarking

We benchmark interest rates using market indicators and comparable instruments, factoring:

currency, tenor, and repayment structure

borrower credit profile (standalone or group support where relevant)

security/collateral, covenants, and subordination

base rate selection and spread support

Credit profile support for intercompany loan benchmarking

We support the analysis of borrower credit profiles and key loan terms to ensure the interest rate benchmark is aligned with comparable market instruments.

India and Global Coverage

India-Focused Studies

For Indian tested parties we benchmark royalty and interest rates against agreements filed with the Indian registries and against decisions of the tribunals and courts, with the Indian taxable base in view.

Global / Country-Specific Studies

For non-Indian tested parties or cross-border licences and loans, we run the study on the tested market's own agreements, currency and credit conditions, using databases recognised in that jurisdiction.

How It Operates

Sourcing Third-Party Agreements

We search public registers, tribunal records and licence databases for agreements over comparable intangibles and for loan instruments with disclosed pricing. Every candidate is logged with its royalty or interest base, territory and term.

Payment Base and Credit Profile

The payment base matters more than the rate. We check whether the licence fee is struck on sales, units or profit, and whether the borrower's credit profile, tenor, currency and security match the tested loan.

Rate and Range Analysis

Once the set holds up, we compute the arm's length rate, with median and interquartile range where the sample allows. Adjustments for territory, exclusivity or credit spread are disclosed line by line.

Documenting the CUP Set

Documentation decides whether the study survives review. We record the search strategy, rejected candidates, adjustments and the reasoning behind each accepted agreement or instrument, in the order a reviewer will read them.

Validation Before Filing

Final validation to ensure the selected agreements are comparable in key terms and conditions and can support a Comparable Uncontrolled Price (CUP) analysis.

Internal CUP Identification and Validation

Where applicable, we identify and evaluate potential internal comparables (third-party agreements within the group) and assess whether they can reliably support a CUP analysis for royalties, services, or financing.

Key Inclusions in Our Reports

Search Strategy and Process Overview

Clear documentation of the search strategy, screening approach, selection logic, and development of the arm’s length range.

Comparable Set and Rejection Rationale

A complete record of selected and rejected items, with structured reasons for acceptance/rejection.

Rate / Fee Schedules and Working Papers

Structured schedules showing selected rates/fees, key assumptions, and computations supporting the final range.

Source References (Supporting Evidence Pack)

References to the sources for the final set of comparable agreements/data points, maintained for audit-ready traceability.

Outcome

Our specialised benchmarking helps ensure royalty pricing, service fees, and interest rates are supported by market evidence and presented in a way that is clear, defensible, and aligned with arm’s length principles across jurisdictions.