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Net Profit Indicator
(38)
Royalty Rates
(13)
Valuation of Intangibles
(13)
CUP Method
(5)
Return on Assets
(5)
Tax Litigation
(5)
Arm's Length Range
(4)
CPM/TNMM
(4)
OECD Profit Indicators
(4)
Economic Substance
(3)
Net profit
(3)
OECD BEPS Action
(3)
Safe Harbors, Safe Harbours
(3)
Comparability Analysis
(2)
OECD adjustment is spurious
(2)
Adjustment
(1)
Australia
(1)
Berry Ratio
(1)
CAPM
(1)
Cumulative effect of advertising on sales
(1)
IRS Releases FY 2015 Data Book
(1)
IRS Releases New Practice Unit
(1)
Intercompany Financing
(1)
Keyword search
(1)
Limited Risk
(1)
Loan Interest Rates
(1)
Location Savings
(1)
Marketing intangibles
(1)
Perpetual Inventory Method (PIM)
(1)
Present Value of Intangibles
(1)
Tax Law
(1)
Text Redaction and Royalty Rates
(1)
US APMA News & Statistics
(1)
see all
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
