Category Transfer Pricing

Transfer Pricing, Operating Profit Markup, Profit Indicators, TNMM/CPM

Theory of Profit Markup in Transfer Pricing

The operating profit margin (OMBD or OMAD) can be derived from the profit markup by indirect least squares (ILS). This is the most theoretically defensible and reliable operating profit indicator that can be obtained from comparable data.

Ednaldo Silva
February 17, 2024

Intangibles, Asia-Pacific, Transfer Pricing, United States

Speculation as to the Transfer Pricing Battle Between Western Digital and the IRS

A discussion of the possible issues in the recently settled transfer pricing dispute between Western Digital Corp. and the United States IRS.

Harold McClure
July 11, 2022

Tax Controversy, Profit Indicators, Transfer Pricing

Tutorial: Power Functions in Transfer Pricing

Regression analysis yields more reliable profit indicators than the linear equation without intercept specified in US and OECD transfer pricing guidelines.

Ednaldo Silva
February 17, 2022

Theory of Profit Markup in Transfer Pricing

Speculation as to the Transfer Pricing Battle Between Western Digital and the IRS

Tutorial: Power Functions in Transfer Pricing

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