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.
A September 19, 2024 ruling by the Portuguese Administrative Arbitration Center upheld the cost-plus approach used by the taxpayer even though the Portuguese tax authorities objected to the exclusion of employee bonus compensation from the cost base. The cost base included certain pass-through costs, which led to the reported markup for 2019 being less than 4.1%.
Topics: TNMM/CPM Portugal Transfer Pricing
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