(redirected from Profit Split Method)
PSMProcess Safety Management (chemical industry)
PSMPorsche Stability Management
PSMPropensity Score Matching (statistics)
PSMParti Sosialis Malaysia (Malay: Socialist Party of Malaysia)
PSMProfessional Science Master's
PSMPlatform-Specific Model(s)
PSMPhase Shifting Mask
PSMPower Supply Module
PSMPersistent Stored Modules
PSMPeran Serta Masyarakat (Indonesian: Community Participation)
PSMPreventive and Social Medicine
PSMPakistan Steel Mills
PSMPlayStation Magazine
PSMPlaystation Move
PSMPlaystation Mobile (gaming)
PSMPengurusan Sumber Manusia (Malay: Division of Human Resources)
PSMProfessional Securities Market
PSMPower Save Mode
PSMPalestine Solidarity Movement
PSMPlatform Support Module
PSMProtection Switch Module
PSMPersistent Storage Manager
PSMProfessional Service Manager
PSMPosition Switching Module
PSMPrinting Systems Manager
PSMPerspective Shadow Mapping
PSMPlatform Specific Model
PSMPascal Symbol
PSMProgram State Manager
PSMPacket Service Module
PSMPacket Storage Manager
PSMPrint Station Manager
PSMPremium Support Manager
PSMPower Seat Module
PSMPlatform Specific Module
PSMPersonal Security Manager
PSMPatient Self-Management
PSMProblem Solving Method
PSMPractical Software Measurement
PSMPartnership for Safe Medicines (various locations)
PSMParish Social Ministry
PSMProtective Security Manual (Australia)
PSMPower Supply Management
PSMProcurement and Supply Management
PSMPublic Service Medal (Australia)
PSMProcess Simulation Model
PSMPurchasing and Supply Management
PSMProduction Stage Manager (theatre)
PSMPublic Service Ministry (various locations)
PSMPublic Service Motivation (motivation grounded in the public sector)
PSMProperty Sales Management
PSMProfessional in Service Management
PSMProgrammable Switch Matrix
PSMPro Sports Media (website design firm)
PSMPersonal Status Message (MSN Messenger/Windows Live Messenger)
PSMPerforated Sheet Metal (manufacturing)
PSMProjector Security Mount
PSMProject Sustainability Management (various organizations)
PSMPersonnel Systems Management
PSMPriorité Santé Mutualiste (French: Priority Health Services Mutual; France)
PSMPacket Switch Module
PSMPrice Sensitivity Measurement (finance)
PSMParaspinal Muscle
PSMPersonnel Status Monitor
PSMProfessional Surveyor and Mapper
PSMParanoia Survivor Max (Dance Dance Revolution song)
PSMPrimary Source Media
PSMProfit Split Method
PSMPharmacy Services Manager
PSMPlastarch Material (thermoplastic resin)
PSMPercussion Sound Module
PSMPicture Status Memory
PSMProtocol Service Multiplexer
PSMPont-Sainte-Maxence (French paper manufacturer)
PSMProgram Security Manager (job title)
PSMProject Safety Manager
PSMProfessional Staff Member (Congress)
PSMPhase Shift Modulation
PSMPhilippine Society for Microbiology, Inc.
PSMPersonal Security Module
PSMPractical Software and System Measurement (Software Capability Maturity Model)
PSMProcurement Strategy Meeting
PSMProduct Safety Management
PSMProactive Server Management
PSMPlease See Me
PSMPoint Source Monitoring
PSMPeace Secretariat for Muslims (Sri Lanka; est. 2004)
PSMPredicator Set Model
PSMProcessor Support Module
PSMPer Switch Matrix (FPGA)
PSMProject Support Manager
PSMPersonal Stock Manager (software)
PSMPan Systolic Murmur
PSMPlasma-Surface Modification
PSMPartner Support Manager
PSMPartial String Matching
PSMPublic Service Modernisation (Ireland)
PSMProject Status Meeting (various organizations)
PSMPersonal Storage Module
PSMPromised Seed Ministries (USA)
PSMPoint Source Modeling
PSMPower Supply Modulator
PSMPassenger Service Manual (airline industry)
PSMParabolic Scattering Model
PSMParalogous Sequence Mismatches
PSMProgram Staff Manager
PSMPortsmouth, NH, USA - Pease International Tradeport (Airport Code)
PSMPersonnel Subsystem Manager
PSMPaddle Stroke Monitor
PSMProduction Services Manager
PSMProcess Sequence Model
PSMPlanned Scheduled Maintenance
PSMProgram Software Manager
PSMPhase-Step Mirror/Monitor
PSMPAM Strike Manager
PSMProperty Sheet Message (Microsoft Windows programming)
PSMPulse Slope Modulation
PSMPatrimoine Sportif et Mécanique (French; Autodrome of Linas Montlhéry historical association)
PSMPortable Space Module
PSMProcess Status Message
PSMProvider Service Management
PSMPractitioner Secure Messaging
PSMProfessional Services Manual
PSMPremio Nazionale Sergio Malavisi (Italian: Sergio Malavisi National Award)
PSMPrestonwood Student Ministry (Plano, TX)
References in periodicals archive ?
TEI commends the OECD for the additional guidance on the use of the profit split method set forth in the Discussion Draft.
Would an appropriate application of the Residual Profit Split Method lead to the IRS's implied conclusion that the manufacturing affiliate is entitled to only half of the consolidated profits?
Earlier, it was difficult for the R and D centres to meet all the five conditions so that they were not subjected to the profit split method.
The taxpayer should identify comparable transactions or companies under the residual profit split method, as it would with any other transfer price method.
Question 6: What aspects of Scenario 2 would need to be elaborated to determine whether a transactional profit split method or another method would be appropriate in this case?
On the other hand, the residual profit split method assumes that the value of an intangible is reflected in its capitalized development expenses.
While profit split and similar methods should remain available for use under the OECD Transfer Pricing Guidelines, as a practical matter we fear that wider use of the profit split method by tax authorities will result in increased controversy and the risk of double taxation.
TEI recommended several revisions to the draft in order to encourage tax administrations to make appropriate adjustments to the taxpayer's TNMM method to ensure comparability rather than encouraging the assertion of the existence of unique intangibles (or highly integrated operations) and substitution of the transactional profit split method for TNMM.
Additional proposed guidance on the application of the transactional profit methods, including the application of the profit split method and the comparability standard to be applied when using TNMM, was developed and added as Part III of Chapter II of the guidelines.
The profit split method, which determines whether transactions are arm's length by reference to what the taxpayer contributes to the combined operating profit or loss of the worldwide organization.
Paragraph 162 states that there are cases where a transactional profit split method would be used as a "sanity check" to test the outcome of a primary pricing method.