The source is a video posted on YouTube
Timeline – Presentation by Valentin Moiseev (video available in Russian language)
0:00 – Introduction. Speech content: general information about tax risks associated with royalty payment. Royalty related claims in cross-border and internal deals. How to avoid risks and properly tackle them where they have already emerged?
2:11 – Study of cases where royalties attract attention of tax authorities
4:46 – Forms of royalty related tax claims
5:54 – Situations with and causes for exclusion of royalty from expenses in full. Case examples
10:27 – Assessment of risks in case of gratuitous assignment of a license
10:54 – Reassessment of the license price by tax authorities
11:59 – Royalty and VAT. Focus on the importance of correct categorization of payment: for royalty or for services in case of a cross-border transaction
12:21 – Risks identification and mitigation. Revealing of the existence of an intellectual property item. Role of documentary evidence of the existence of know-how. Determining of the business goal of a deal, special attention to the role of the licensor