The TP Guides Library
Downloadable step-by-step guides for transfer pricing analysis and implementation.
Guide
THE ARM’S LENGTH RANGE
How to Run a Benchmarking Analysis
How comparable company studies establish a defensible arm's length range, from the arm's length principle and method selection through the full screening workflow to the documented range.
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How to Run a Royalty Benchmarking Analysis
Building a defensible arm's-length royalty rate from third-party license agreements.
How to Run a Value Chain Analysis
Mapping value drivers to the entities that control them and testing profit alignment.
How to Run a Profit Split Analysis
Separating routine from non-routine contributions and building a defensible residual allocation.
How to Run an Intercompany Loan Benchmarking Analysis
From delineation through debt capacity, credit rating and yield construction to a documented range.
How to Set Up a Cash Pool
Standing up an intra-group cash pool in five phases, with the TP decisions built into each.
How to Set Up a Cost Allocation
Pricing management fees, charge-outs and headquarter charges, from benefit test to mark-up.
How to Set Up an IP Migration
Valuation, exit charges, and making substance follow title when intangibles move within a group.
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Country-by-country documentation rules, open-access tools, and articles on transfer pricing concepts all live back on the resources hub.