NERA Director Amanda Pletz and Affiliated Consultant Mark Berenblut wrote “Transfer Pricing Considerations for Intercompany Cryptocurrency” in Applying the Arm’s Length Principle to Intra Group Financial Transactions: A Reference Guide. Their chapter provides an overview of factors affecting the financial dynamics and associated risks of crypto funding and resulting considerations for transfer pricing. The authors give suggestions for using standard pricing tools and methods to adjust for the difference in risks between transitional funding and crypto funding. 

Order Applying the Arm’s Length Principle to Intra Group Financial Transactions: A Reference Guide from Wolters Kluwer here.