In order to better understand what royalties are, it is important to define the term ‘intangibles’. According to the definition given in paragraph 6.6 of Section A of the final report of Action 8 published by OECD on 5th October of 2015 under the Base Erosion and Profit Shifting (BEPS) initiative: ‘Intangible is intended to address something which is not a physical asset or a financial asset, which is capable of being owned or controlled for use in commercial activities, and whose use or transfer would be compensated had it occurred in a transaction between independent parties in comparable circumstances’.