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.
In this tutorial, we address comparability adjustments for differences in the currency of the tested loan to that of the comparable transactions.
Topics: Tutorial CUFT Interest Rates Financial Transactions Intercompany FinancingRead 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
In this tutorial we introduce you to a tool in the EdgarStat CUFT Loan Agreements Database for estimating the implied credit rating of your tested borrower using the Altman Z”-Score Model.
Topics: Credit Rating CUFT Intercompany FinancingRead more
Intercompany financing is a growing area of focus in transfer pricing. CUFT Analytics co-founder and managing director John Hollas provides guidance on using the EdgarStat CUFT Loan Agreements Database to benchmark an arm's length range of interest rates.
Topics: CUFT Credit Risk Intercompany Financing Arm's Length Interest RatesRead more
Interests fluctuate based on market conditions, and analysts must consider whether the market conditions surrounding their data are comparable to those of the tested intercompany transaction when benchmarking an arm's length interest rate in transfer pricing.
Topics: CUFT Interest Rates Intercompany FinancingRead more