Stock-based Compensation and the Arm’s Length Principle
I. Introduction Inclusion or deduction of stock-based compensation (“SBC”)[1], to be defined herein, in a cost base when applying the Transactional Net Margin Method (“TNMM”)[2] / Comparable Profits Method (“CPM”)[3] has been an ongoing transfer pricing (“TP”) discussion in recent years. As will be detailed in this article, several countries have attempted to publish legislation to address […]