Transfer Pricing

Our experts work along with our clients and their legal advisors in identifying their transfer pricing.

In order to determine the most appropriate transfer pricing method against which the controlled transaction can be compared, it is necessary to examine each of the methods recognised by the OECD. The steps to select the correct transfer pricing method are as follows:

  • The availability of credible information (especially for comparable uncontrolled companies) necessary for the application of the chosen method
  • The accuracy of the method considered with regard to the nature of the controlled transaction
  • The degree of comparability between controlled and uncontrolled transactions

The OECD provides five methods for determining arm’s length prices:

  • The comparable uncontrolled price method (CUP)
  • The resale price method (RPM)
  • The Cost Plus method (CP)
  • The transactional net margin method (TNMM)
  • The transactional profit split method (TPSM)

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