Profit-split Considerations in TNMM Solutions in a Post-BEPS World

12 December 2018
Yves Hervé, Philip de Homont

NERA Managing Director Yves Hervé and Associate Director Philip de Homont published the article “Profit-split considerations in TNMM solutions in a post-BEPS world” in International Tax Review. It is the fourth article in their series on transfer pricing technical challenges and solutions brought about by the changing regulatory and economic landscapes for global multinational entities. The authors previously explained how setting and testing transfer prices via the transactional net margin method (TNMM) will come under more scrutiny now that tax authorities take a wider interpretation of local entrepreneurial contributions. In light of this, they explain a case study that illustrates their approach to an enhanced TNMM model with an embedded profit-split analysis.

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