Blog

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.

Fixed-Rate Intercompany Loans and Currency Denomination
September 12, 2022 by Harold McClure

Harold McClure expounds on the issue of currency denomination in intercompany financing, addressing currency adjustments in longer-term fixed interest rates, past controversies, and regulatory guidance.

Topics: Financial Transactions OECD United Nations Adjustments Intercompany Financing Arm's Length Interest Rates

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Tutorial: Country Risk Adjustment in Intercompany Financing
May 26, 2022 by John Hollas

One of the most challenging transfer pricing issues regarding financial transactions is making a comparability adjustment for differences in country risk between the tested non-US borrower’s country and the comparable US borrower's country in pricing the intercompany loan interest rate.

Topics: CUFT State Transfer Pricing Adjustments Intercompany Financing Arm's Length Interest Rates

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