EYEY

US Tax Court increases Medtronic royalty rate under unspecified method

|Tax Alerts, National/Federal Taxation, T ...|United States, Puerto Rico
United States, Puerto Rico

  • The Tax Court applied an unspecified method in its transfer pricing analysis to determine the royalty rates for license agreements between Medtronic US and its Puerto Rican subsidiary.

  • The Tax Court rejected the IRS’s use of the Comparable Profits Method (CPM) and Medtronic US’s application of the comparable uncontrolled transaction (CUT) method.

  • The Tax Court’s opinion in Medtronic III provides …

Continue Reading