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.
Harold McClure expounds on the issue of currency denomination in intercompany financing, addressing currency adjustments in longer-term fixed interest rates, past controversies, and regulatory guidance.
Topics: Financial Transactions OECD United Nations Adjustments Intercompany Financing Arm's Length Interest RatesRead more
One 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 RatesRead more