TNMM in a Post-BEPS World—New Transfer Pricing Solution Requirements

12 July 2018
Yves Hervé and Philip de Homont

NERA Managing Director Yves Hervé and Associate Director Philip de Homont published the article “TNMM in a post-BEPS world—new transfer pricing solution requirements” in International Tax Review. It is the second article in their series on transfer pricing technical challenges and solutions brought about by the changing regulatory and economic landscapes for global multinational entities. In this article, the authors discuss how the transactional net margin method (TNMM) needs to be enhanced in light of the guidelines of the OECD base erosion and profit shifting (BEPS) initiative so that transfer pricing structures defended through application of TNMM remain sustainable in the future. 

The first article in the authors’ International Tax Review series can be found here.