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.
Use of the CPM/TNMM to determine royalty rates for valuable intangibles in transfer pricing is incompatible with basic financial economics.
Topics: DEMPE Royalty Rates OECD Guidelines US Internal Revenue Service Intangibles Tax Policy TNMM/CPMRead more
The Israel Tax Authority is questioning whether costs plus markup models Israeli R&D affiliates are at arm's length. This could present issues for multinationals that have not been giving proper consideration to cost base, asset intensity and ownership of valuable intangibles in their benchmarking.
Topics: DEMPE Base Erosion and Profit Shifting (BEPS) Benchmarking Intangibles Tax PolicyRead more