RoyaltyStat Blog

Brazil to Adopt the Arm’s Length Principle and OECD-aligned Transfer Pricing Rules

Operating Profit Indicators Using Robust Regression

Reliable Profit Indicators Using Regression Analysis

Return on Assets is Détaché from Economics

Rate of Return on Capital Employed is Misconceived

Crude Oil and Natural Gas Prices are Random Walks

Asset Intensity Adjustments in Transfer Pricing Lack Merit

ITAT Transfer Pricing Decision on Use of the Resale Price Method

Transfer Pricing and Financial Transactions in the UN Manual, OECD Guidelines and Brazil

Pfizer’s Galactic Operating Profit Markup

Working Capital Adjustments in Transfer Pricing

Should Brazil Adopt the OECD Guidance on Intercompany Financing?

Transfer Pricing Issues in Cloud Computing

Multi-Year Analysis of Profit Indicators

Return on Operating Assets Using Error Corrected Regression

Practical Guide to Location Savings Analysis in Transfer Pricing

Return on Assets (ROA) is Unreliable in Transfer Pricing

Transfer Pricing and the Burden of Proof in Australia

The Cumulative Advertising Effects on Sales

The CPM/TNMM is a Multiplier Theory

The Berry Ratio is Illegitimate Under the TNMM

A Proposed Transfer Pricing Safe Harbor for US Retailers

Danish Tax Court: Valuation of Intangibles and the DCF Model

The Premature Death of the Comparable Uncontrolled Transaction (Price) Method

Oligopoly Profit Markup

Adecco Intercompany Royalty Litigation: CUP v. TNMM

The Limited Risk Transfer Pricing Canard During a Pandemic

The CAPM is Misapplied in Transfer Pricing

Controversy Aside, IKEA on Solid Economic Footing in Royalty Dispute

Creating Defensible Transfer Pricing Reports

Translating Credit Ratings into Credit Spreads in Intercompany Financing

Return on Assets When Assets are Exogenous

The Standard Measure of Return on Assets is Biased

Safe Harbors for U.S. Retailers

Transfer Prices Based on EBITDA, not EBIT

Transfer Pricing Methods Based on Operating Profits

The “Return on Assets” Excludes Self-Developed Intangibles

Effect of Text Redaction on Royalty Rates and Other Licensing Terms

Royalty Rates for Licensed Intangibles and Minerals

Another Look at Estimating Reliable Profit Indicators in Transfer Pricing

Transfer Pricing Profit Indicators Using All Available Data

Corporate Reorganizations in Transfer Pricing Need Economic Substance

Applying Regression Analysis to Transfer Pricing's CUP Method

The Profit Margin of US Retailers in Transfer Pricing

The Profit Markup Model in Transfer Pricing

Another Look at Using ROA in Transfer Pricing

Return on Assets Using Adaptive Expectations in Transfer Pricing

Alternative Functional Forms of Comparable Profits in Transfer Pricing

Selecting Reliable Profit Indicators in Transfer Pricing

Present Value of Intangibles in Transfer Pricing

Profit Margin Using Koyck Transform in Transfer Pricing

Return on Assets (ROA) is An Unreliable Profit Indicator in Transfer Pricing

Intangible Assets in Transfer Pricing Are Not Hard-to-Value

Transfer Pricing Memento

Location Savings Adjustment to Profits in Transfer Pricing

Profit Margin by Indirect Least Squares in Transfer Pricing

Selecting the Appropriate “Net” profit indicator (NPI) in Transfer Pricing

Coefficient of Variation of Return on Assets Used in Transfer Pricing

Most Reliable Transfer Pricing Profit Indicator Based on Coefficient of Variation

Using a distributed lag model to determine arm’s length profits in transfer pricing

US and OECD Method for Computing arm’s Length Profit Margin in Transfer Pricing is Flawed

Surplus Bargaining and the Effect of Contract Redaction on Royalties

OECD Inventory Adjustment to Profits in Transfer Pricing is Spurious

Adjusted COGS is a Proxy for Purchases in Transfer Pricing

Hard-to-Value Intangibles Sans Mystere in Transfer Pricing

Arm’s Length Profit Margin in Transfer Pricing

Equilibrium Arm’s Length Profit Ratios in Transfer Pricing

Enterprise Profits in Transfer Pricing

Residual Profit Split in Transfer Pricing is an Avoidable Cul-de-Sac

Forecasting Profit Margin Under CWI in Transfer Pricing

The AR(1) Model of the Profit Margin in Transfer Pricing

Determining Arm's Length Profit Margins Using the AR(1) Model in Transfer Pricing

Operating Profit Margins Don't Obey the Normal Distribution

Royalty Rates for Medical Devices

Double Log Operating Profit Margin

RoyaltyStat Keyword Search

Profit Margin with Heterogeneous Variance

Gross Profit Methods are Unreliable

Profit Margin Using a Power Function

Profit Margin of Corporate Innovators & Imitators

IRS International Practice Units

Selection of the PLI - Profit Margin

Valuation of Intangibles: Pfizer Example

Royalty Rates for Utility Patents

Valuation of Intangibles: Measuring Excess Returns

IRS Releases FY 2015 Data Book

Valuation of Intangibles Based on Lagged Investments

Economic Substance: Controlled Reorg Must Lead to Higher Profits

US APMA Program, 2015 APA Statistics

Valuation of Intangibles: Present Value Method

Risk-Adjusted Asset Return

Cross-Country Royalty Rates Converge

OECD Released the Country-by-Country XML Schema

Arm's Length Range - Most Reliable Measure

Valuation of Intangibles From Initial Capital Stock

Return on Assets - Correct Measure

Valuation of Intangibles Based on the Perpetual Inventory Method (PIM)

Royalty Rates in Patent Infringement

Royalty Rates Are Stable Across Industries

Intangibles Are Not Hard to Value

Present Value of Intangibles May Not Be Realized

Royalty Rates Are Great Ratios (Bis)

Royalty Rates Are Great Ratios

Comparable Royalty Rates

Corporate Reorganizations Without Economic Substance

Royalty Rates Large & Small