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.
This blog presents a basic analytical framework for understanding the relationship between GDP growth and public debt commitments. The Harrod-Domar principle, which posits that increased gross private domestic fixed non-residential investment drives GDP growth, does not apply to the recent GDP growth of many countries.
Topics: United States Europe
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 Asia-Pacific Transfer Pricing United States
Read moreHarold 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 Europe
Read moreInternational 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 France United States Intercompany Financing
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