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.
A 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 Transfer Pricing Asia-PacificRead more
Harold McClure explores intercompany financing issues through the lens of a recent case before the EU General Court and an upcoming battle between Perrigo and the IRS.
Topics: Interest Rates United States Intercompany Financing EuropeRead more
International tax law firms are rightfully warning clients of audit risks with respect to intercompany financing in France. Taxpayers can mitigate risk by following new OECD guidance, providing sound economic analysis and avoiding overly aggressive positions on group vs. standalone credit ratings.
Topics: Interest Rates United States France Intercompany FinancingRead more