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.
This discussion presents a simplified illustration of the issues with respect to the unspecified method applied in Medtronic III in contrast to the IRS' extreme CPM approach and a traditional RPSM approach based on sound financial economics.
Topics: Residual Profit Split Method Medtronic Unspecified Method US Internal Revenue Service Section 482 Tax Policy tax controversy Intangibles TNMM/CPM US Transfer Pricing
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