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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Intercompany Financing: Engie State Aid Case and Perrigo’s Battle with the IRS
May 31, 2021 by Harold McClure

Harold McClure explores intercompany financing issues through the lens of a recent case before the EU General Court and an upcoming battle between Perrigo and the IRS.

Topics: Interest Rates Europe United States Intercompany Financing

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Challenges to Intercompany Loan Rates by French Tax Authority and IRS
May 07, 2021 by Harold McClure

International tax law firms are rightfully warning clients of audit risks with respect to intercompany financing in France. Taxpayers can mitigate risk by following new OECD guidance, providing sound economic analysis and avoiding overly aggressive positions on group vs. standalone credit ratings.

Topics: Interest Rates United States France Intercompany Financing

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