Blog

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. Blog writings reflect the position of the authors and are not the opinion of EdgarStat.

Fixed-Rate Intercompany Loans and Currency Denomination
September 12, 2022 by Harold McClure

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 Rates

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Tutorial: Currency Adjustments in Intercompany Financing
August 03, 2022 by John Hollas

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 Financing

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