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.

Nestle Portugal: Issues with Comparables' Royalty Bases
May 15, 2023 by Harold McClure

This litigation raised an oft-seen issue as to the correct definition of “sales” for transfer pricing approaches that rely on the Comparable Uncontrolled Transaction (Price) method.

Topics: Intangibles Comparable Uncontrolled Transaction (Price) Method Portugal Royalty Base Royalty Rates

Read more
EdgarStat LLC
5425 Wisconsin Ave., Suite 600
Chevy Chase, MD, 20815-3577
Customer Support