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 operating profit margin (OMBD or OMAD) can be derived from the profit markup by indirect least squares (ILS). This is the most theoretically defensible and reliable operating profit indicator that can be obtained from comparable data.
Topics: Transfer Pricing TNMM/CPM Operating Profit Markup Profit Indicators
Read moreA discussion of the possible issues in the recently settled transfer pricing dispute between Western Digital Corp. and the United States IRS.
Topics: Intangibles United States Asia-Pacific Transfer Pricing
Read moreRegression analysis yields more reliable profit indicators than the linear equation without intercept specified in US and OECD transfer pricing guidelines.
Topics: Tax Controversy Transfer Pricing Profit Indicators
Read more