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.

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

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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

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