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.
The Swiss Federal Court ruled in favor of the tax authorities on July 17, 2024 in a litigation that frames a Swiss debate over the role of the annual circular on safe harbor interest rates issued by the Swiss Federal Tax Administration.
Topics: Credit Rating Arm's Length Interest Rates Intercompany Loans
Read moreThe 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 Financing Intercompany Loans US Transfer Pricing Canada Revenue Agency
Read moreThe Dutch tax authority prevailed in its challenge of several British American Tobacco intercompany financing transactions.
Topics: Intercompany Guarantee Fees Intercompany Financing Arm's Length Interest Rates Intercompany Loans
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