Super Royalties in Transfer Pricing: Going Beyond “Economics 101”
Use of the CPM/TNMM to determine royalty rates for valuable intangibles in transfer pricing is incompatible with basic financial economics.
Category OECD Guidelines
Brazil’s Alignment with OECD Transfer Pricing Guidelines: The Marcopolo Case
Brazil’s unique transfer pricing rules have allowed multinationals to shift income to tax havens in certain situations. We explore through the lens of the Macopolo case how Brazil could benefit from adoption of the arm's length standard.