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.
The Israel Tax Authority prevailed in Israel vs CA Software Israel Ltd (October 2022, Tel Aviv District Court, Case No 61226-06-17), which involved the valuation of transferred software. While the taxpayer’s experts tried to justify the lower valuation arguing that the economic useful life of the transferred intangibles was very short.
Topics: Discounted Cash Flow Intangibles Valuation of Intangibles Tax ControversyRead more
There are several approaches to accounting for ongoing marketing expenses necessary to maintain a brand in a discounted cash flow valuation.
Topics: Intangibles France Valuation of IntangiblesRead more