The EdgarStat Blog explores issues in transfer pricing and application of the transactional net margin method (TNMM or CPM in the US) and other enterprise profit-based methods. Blog writings reflect the position of the authors and are not the opinion of EdgarStat.
In this tutorial, we address comparability adjustments for differences in the currency of the tested loan to that of the comparable transactions.
Topics: Tutorial CUFT Interest Rates Financial Transactions Intercompany Financing
Read moreOne of the most challenging transfer pricing issues regarding financial transactions is making a comparability adjustment for differences in country risk between the tested non-US borrower’s country and the comparable US borrower's country in pricing the intercompany loan interest rate.
Topics: CUFT State Transfer Pricing Adjustments Intercompany Financing Arm's Length Interest Rates
Read moreIn this tutorial we introduce you to a tool in the EdgarStat CUFT Loan Agreements Database for estimating the implied credit rating of your tested borrower using the Altman Z”-Score Model.
Topics: CUFT Intercompany Financing Credit Rating
Read moreIntercompany financing is a growing area of focus in transfer pricing. CUFT Analytics co-founder and managing director John Hollas provides guidance on using the EdgarStat CUFT Loan Agreements Database to benchmark an arm's length range of interest rates.
Topics: CUFT Credit Risk Intercompany Financing Arm's Length Interest Rates
Read more