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.

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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RPM vs. TNMM: Benchmarking a LATAM Pharmaceutical Distributor
October 20, 2021 by Harold McClure

To determine whether the usual financial ratios provide insights into what would represent an arm's length range, any analysis of controlled healthcare distributors must account for the underlying facts surrounding the functions and expenses occurred by the distribution affiliate.

Topics: Pharmaceutical Industry Benchmarking TNMM/CPM Tax Controversy Resale Price Method

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