What does this research mean for the field?

In cross-border litigation funding structures, residual returns should be allocated partly based on non-routine investment-management and governance contributions rather than solely on capital provision. Novelty: ClaimNovelty.METHODOLOGICAL. Consensus alignment: ConsensusAlignment.NEUTRAL.

What question did this study set out to answer?

To develop a transfer pricing framework that differentiates capital returns, management fees, and performance returns across cross-border litigation funding structures.

September 5, 2026International Transfer Pricing Journal

Transfer Pricing in Litigation Funding: Remunerating Cross-Border Value-Creating Functions

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Authors

FMFilippo Miotto

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Overview

Conceptual analysis demonstrates profit allocation models in cross-border litigation funding, indicating that residual returns must reward non-routine governance and management alongside capital.

Key Points

To develop a transfer pricing framework that differentiates capital returns, management fees, and performance returns across cross-border litigation funding structures.
Mapped value-creating platform functions—including origination, underwriting, monitoring, and enforcement—to specific revenue categories.
Evaluated the applicability of CUP, TNMM, cost-plus, and transactional profit-split methods for allocating income across multinational entities.
Demonstrated that traditional capital provision alone does not justify full entitlement to residual and performance returns in cross-border funding models.
Identified that non-routine investment management, legal underwriting, and ongoing governance functions warrant residual profit shares via profit-split mechanisms.

Cite This Study

Filippo Miotto (2026) studied this question.

synapsesocial.com/papers/6a9bd3e16b95aff0620eb075 https://doi.org/10.59403/33tt60t

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September 5, 2026International Transfer Pricing Journal

Transfer Pricing in Litigation Funding: Remunerating Cross-Border Value-Creating Functions

View Full Paper

Ask AI

Bookmark

Authors

FMFilippo Miotto

Discussion

Member takes

Overview

Conceptual analysis demonstrates profit allocation models in cross-border litigation funding, indicating that residual returns must reward non-routine governance and management alongside capital.

Key Points

To develop a transfer pricing framework that differentiates capital returns, management fees, and performance returns across cross-border litigation funding structures.
Mapped value-creating platform functions—including origination, underwriting, monitoring, and enforcement—to specific revenue categories.
Evaluated the applicability of CUP, TNMM, cost-plus, and transactional profit-split methods for allocating income across multinational entities.
Demonstrated that traditional capital provision alone does not justify full entitlement to residual and performance returns in cross-border funding models.
Identified that non-routine investment management, legal underwriting, and ongoing governance functions warrant residual profit shares via profit-split mechanisms.

Cite This Study

Filippo Miotto (2026) studied this question.

synapsesocial.com/papers/6a9bd3e16b95aff0620eb075 https://doi.org/10.59403/33tt60t

View Full Paper

Ask AI

Bookmark