Archive for November 3rd, 2010

A mini case-study in residual profit split transfer pricing

November 3, 2010  |  Transfer Pricing  |  No Comments

A beautifully taken picture of an unpainted JAL cargo plane taking off from a US airport.

A Tax Tribunal appeal case (the ‘Appeal’) reported on 28 June 2010 provides a useful ‘mini case study’ in the application of a residual profit split transfer pricing methodology.  The Appeal reviewed the identification of key intangible assets, issues in the choice of an appropriate third party comparable and the use of an appropriate allocation factor in the method concerned.  This article reports the facts and findings in the case concerned. Read More