Customs valuation of royalty requires a direct imported-goods nexus and payment as a condition of sale.

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....Royalty and licence fees may be included in the customs transaction value only where Revenue establishes a direct and proximate relationship with the imported goods and proves that payment is a condition of their sale. The explanation concerning post-import processing does not independently expand these requirements. Royalties payable for technology transfer, intellectual property, or post-import manufacturing rights are not linked to imports merely through a broad commercial connection. Where royalty arises from manufacture and sale of finished products, is neither conditional on component imports nor calculated by their value or quantity, it is not includible in the assessable value of imported components.....