Category CUP

Intercompany Services, CUP, Management Fees, State Transfer Pricing, TNMM/CPM

Intercompany Management Fees: CUP v. CPM (TNMM)

Transfer pricing practitioners in the US as well as in other nations often face the dilemma that clients wish to establish intercompany management fees as a percentage of revenues while tax authorities may test the implied cost plus from any intercompany management policy.

Harold McClure
October 12, 2022

Resale Price Method, CUP, Oil and Gas Transfer Pricing, TNMM/CPM

Transfer Pricing Issues in Italian Imports of Russian Natural Gas

Italy’s Supreme Court remanded May 17, 2022 a case in which Regional Tax Commission of Lombardy challenged the transfer pricing between Promgas Spa and Gazprom Export, finding alleged deficiency in the tax authority’s application of the Transactional Net Margin Method (TNMM).

Harold McClure
August 9, 2022

Intercompany Management Fees: CUP v. CPM (TNMM)

Transfer Pricing Issues in Italian Imports of Russian Natural Gas

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