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.

Intercompany Management Fees: CUP v. CPM (TNMM)
October 19, 2022 by Harold McClure

Transfer pricing practitioners in the US as well as in other nations often face the dilemma that clients wish to establish intercompany management fees as a percentage of revenues while tax authorities may test the implied cost plus from any intercompany management policy.

Topics: TNMM/CPM Intercompany Services Management Fees CUP State Transfer Pricing

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Transfer Pricing Issues in Italian Imports of Russian Natural Gas
August 16, 2022 by Harold McClure

Italy’s Supreme Court remanded May 17, 2022 a case in which Regional Tax Commission of Lombardy challenged the transfer pricing between Promgas Spa and Gazprom Export, finding alleged deficiency in the tax authority’s application of the Transactional Net Margin Method (TNMM).

Topics: TNMM/CPM Resale Price Method Oil and Gas Transfer Pricing CUP

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