This blog presents a basic analytical framework for understanding the relationship between GDP growth and public debt commitments. The Harrod-Domar principle, which posits that increased gross private domestic fixed non-residential investment drives GDP growth, does not apply to the recent GDP growth of many countries.
A 2008 restructuring transferred the European rights to the McDonald’s intangibles to McD Europe Franchising Sàrl, a Luxembourg-resident subsidiary with branches in both Switzerland and the U.S. While this migration of intangible assets created substantial controversy in Europe, the real transfer pricing concern would be an IRS issue and not an issue for the French Tax Authority (FTA) if the royalty rate remained at 5%.
Harold McClure explores intercompany financing issues through the lens of a recent case before the EU General Court and an upcoming battle between Perrigo and the IRS.