Oil and Gas Transfer Pricing

Topics

Interest Rates
Intercompany Financing
Credit Rating
Arm's Length Interest Rates
Comparability
Limited Risk Distributor
TNMM/CPM
Profit Indicators
Intercompany Loans
State Transfer Pricing
Tax Controversy
Tax Policy
Base Erosion and Profit Shifting (BEPS)
Brazil
OECD Guidelines
DEMPE
Intangibles
Royalty Rates
US Internal Revenue Service
United States
Asia-Pacific
Transfer Pricing
CUFT
Adjustments
France
Discounted Cash Flow
Valuation
Valuation of Intangibles
Tutorial
Financial Transactions
Pharmaceutical Industry
Intercompany Services
Management Fees
CUP
Portugal Transfer Pricing
Asset Intensity Adjustment
Comparable Uncontrolled Transaction (Price) Method
Portugal
Royalty Base
OECD
United Nations
Operating Profit Markup
Financial Economics
Benchmarking
CAPM
Return on Assets
Contract Manufacturer
Australia
Australian Tax Office
Singapore
Procurement Hub
Residual Profit Split Method
Unspecified Method
Medtronic
Section 482
US Transfer Pricing
Credit Risk
Intercompany Guarantee Fees
Canada Revenue Agency
Europe
Best Method
Mining and Extractives
Canadian Revenue Agency
Corporate Profits
Oligopoly
Arm's Length Principle
Resale Price Method
Oil and Gas Transfer Pricing

Operating Profit Margin of U.S. Big Oil

December 11, 2023 by Ednaldo Silva

Data suggest that “big oil” forms an oligopoly industry. Noise about oil and gas prices being determined by supply and demand is suspect.

Topics: Oil and Gas Transfer Pricing Profit Indicators US Transfer Pricing

Transfer Pricing Issues in Italian Imports of Russian Natural Gas

August 16, 2022 by Harold McClure

Italy’s Supreme Court remanded May 17, 2022 a case in which Regional Tax Commission of Lombardy challenged the transfer pricing between Promgas Spa and Gazprom Export, finding alleged deficiency in the tax authority’s application of the Transactional Net Margin Method (TNMM).

Topics: Resale Price Method CUP Oil and Gas Transfer Pricing TNMM/CPM