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 Dutch tax authority prevailed in its challenge of several British American Tobacco intercompany financing transactions.
Topics: Intercompany Financing Intercompany Guarantee Fees Arm's Length Interest Rates Intercompany Loans
Read moreHarold 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
Read moreOne 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
Read moreIntercompany financing is a growing area of focus in transfer pricing. CUFT Analytics co-founder and managing director John Hollas provides guidance on using the EdgarStat CUFT Loan Agreements Database to benchmark an arm's length range of interest rates.
Topics: CUFT Credit Risk Intercompany Financing Arm's Length Interest Rates
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