Expert commentary on comparable company studies, benchmarking methods, and regulatory compliance. Resources for in-house tax professionals and transfer pricing advisors.
ArticleHow to conduct a FAR analysis for transfer pricing: what to look for in functions, assets, and risks, with a concrete walkthrough for an intercompany software engineering arrangement.
ArticleA practical guide to transfer pricing for intercompany services: how to categorize services, select the right pricing method, establish arm's length charges, and avoid the most common compliance pitfalls.
ArticleHow the net cost plus markup works as a profit level indicator in transfer pricing benchmarking studies, when to use it, how to calculate it, and where practitioners get it wrong.
ArticleWhy most benchmarking studies fail on audit, how the comparable search process works, and what separates a defensible analysis from a mechanical one.
ArticleA practitioner's guide to the five transfer pricing methods. Why TNMM/CPM is the answer for most routine transactions, when profit split applies, and how to document method selection.
ArticleA practitioner's guide to transfer pricing studies: what they contain, when they are required, how the process works from scoping to final report, and what they typically cost.
ArticleNavigate the intersection of transfer pricing and customs valuation in the current US tariff environment, including the First Sale rule, year-end adjustments, and CBP-IRS coordination challenges.
ArticlePractical guidance on structuring global management fee charge-outs: benefit tests, allocation keys, markup levels, and the documentation needed to defend intercompany service charges.
ArticleA practical look at transfer pricing for consumer goods multinationals: brand IP, distribution structures, marketing intangibles, and the challenges of e-commerce and direct-to-consumer models.
ArticleExplore the emerging transfer pricing issues in artificial intelligence: training data ownership, model IP location, GPU compute allocation, and how AI business models challenge traditional benchmarking.
ArticleA deep dive into transfer pricing for software and SaaS companies, including IP migration, cost-sharing arrangements, distribution structures, and the unique challenges of digital business models.
ArticleLearn what a transfer pricing benchmarking study contains, the methodology choices that determine its quality, and how the same data can produce different arm's length ranges across jurisdictions.