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.

Speculation as to the Transfer Pricing Battle Between Western Digital and the IRS
July 11, 2022 by Harold McClure

A discussion of the possible issues in the recently settled transfer pricing dispute between Western Digital Corp. and the United States IRS.

Topics: United States Transfer Pricing Asia-Pacific Intangibles

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Tutorial: Power Functions in Transfer Pricing
February 18, 2022 by Ednaldo Silva

Regression analysis yields more reliable profit indicators than the linear equation without intercept specified in US and OECD transfer pricing guidelines.

Topics: Profit Indicators Tax Controversy Transfer Pricing

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