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.

Implicit Support in the US and Canada: Perrigo and GE Capital Canada
March 30, 2024 by Harold McClure

The IRS has recently asserted implicit support in several situations where a foreign based affiliate extended an intercompany loan to a US borrowing affiliate. In this piece, we'll discuss an intercompany loan involving Perrigo, and compare the IRS settlement to the litigation involving GE Capital Canada before we turn to another potential IRS issue.

Topics: US Internal Revenue Service Intercompany Guarantee Fees Intercompany Loans Intercompany Financing US Transfer Pricing Canada Revenue Agency

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Dutch Tax Authority Wins Challenge of British American Tobacco's Intercompany Financing
November 10, 2022 by Harold McClure

The Dutch tax authority prevailed in its challenge of several British American Tobacco intercompany financing transactions.

Topics: Arm's Length Interest Rates Intercompany Guarantee Fees Intercompany Loans Intercompany Financing

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