A royalty, by default, is still payment for something. Take two identical cars, one with the Audi brand, and one without. What's the brand value now then? You s

A royalty, by default, is still payment for something. Take two identical cars, one with the Audi brand, and one without. What's the brand value now then? You should be able to deduct a part of your profit if said IP is held in a lower tax jurisdiction, which will almost always be the case, since multinationals have bases in many different countries.