Deloitte US

Marco Fiaccadori, Arindam Mitra, and Robert Plunkett explain how to reconcile the licensor-licensee profit split approach with the income approach.

As energy firms discover and exploit new reserves which require significant amounts of financing, tax authorities have increased their focus on the intra-group financing transactions of such companies. Randy Price, Nadim Rahman and Bill Yohana of Deloitte investigate why the materiality of these transactions may have also increased taxation authority interest in the intra-group financing transactions of energy firms.