In this article from International Tax Review, NERA Special Consultant Dr. Alexander Voegele, Vice President Dr. Stuart Harshbarger, and former Vice President Nihan Mert-Beydilli address how to calculate an arm’s length royalty rate for intercompany licensing of intellectual property (IP) after showing how application of the existing US and European methods for IP valuation provides taxpayers with an incomplete answer. The authors show that a complete and acceptable approach for tax authorities is to obtain comparable market opinions from industry experts. The authors have successfully used this approach with European tax authorities in the past.