Documentation Requirements
Transfer Pricing Penalties: How to Estimate Your Exposure
Understand US §6662(e) and §6662(h) penalty thresholds, documentation defenses, and how to estimate transfer pricing penalty exposure for your multinational group.
Articles and News
More articles
TP Methods
5 min
FAR Analysis in Transfer Pricing: Functions, Assets, and Risks Explained
How 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.
Cost Allocation
6 min
Intercompany Services Transfer Pricing: How to Structure, Price, and Document Service Charges
A 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.
Benchmarking Analysis
5 min
Net Cost Plus Markup in Transfer Pricing: When and How to Apply It
How 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.
Benchmarking Analysis
9 min
Transfer Pricing Benchmarking Analysis: From Comparable Search to Arm's Length Range
Why most benchmarking studies fail on audit, how the comparable search process works, and what separates a defensible analysis from a mechanical one.
TP Methods
6 min
Transfer Pricing Methods Explained: How to Choose the Right One
A 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.
TP Methods
7 min
What Is a Transfer Pricing Study? Scope, Process, and Deliverables
A 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.
Transfer Pricing and Tax
10 min
Transfer Pricing and Customs: Coordination Under a Shifting Tariff Regime
Navigate 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.
Cost Allocation
11 min
Global Management Fee Charge-Outs: Pricing, Allocation, and Documentation
Practical guidance on structuring global management fee charge-outs: benefit tests, allocation keys, markup levels, and the documentation needed to defend intercompany service charges.
Consumer Goods
10 min
Transfer Pricing in the Consumer Goods Sector: A Sector Deep Dive
A 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.
Transfer Pricing AI
7 min
Transfer Pricing in Artificial Intelligence: A Sector Deep Dive
Explore 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.
Technology
7 min
Transfer Pricing in the Technology Sector: A Sector Deep Dive
A 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.
Benchmarking Analysis
8 min
Inside a Transfer Pricing Benchmarking Study: What It Is and Why It Matters
Learn 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.
Industrial Manufacturing
8 min
Transfer Pricing in Industrial Manufacturing: A Sector Deep Dive
A practical examination of transfer pricing for industrial manufacturing groups: manufacturer characterization (full-fledged, contract, toll), the aftermarket and service-parts business, engineering and NRE charge-outs, joint ventures and licensing, and the interaction with customs and Section 232 tariffs.
IP & DEMPE
12 min
IP Transfer and Exit Taxation: Transfer Pricing Considerations
The transfer pricing analysis of a cross-border restructuring: the before-and-after functional profile, testing the terms, and pricing the exit charge.
IP & DEMPE
14 min
DEMPE in Practice: Aligning Intangible Returns with Functions, Risk, and Control
How intangible returns follow the entities that perform the DEMPE functions and control the risks, not the bare legal owner, and how to evidence where value sits.
Consumer Goods
8 min
Transfer Pricing in Consumer Electronics: A Sector Deep Dive
A practical examination of transfer pricing for consumer electronics groups: layered IP value chains, contract and toll manufacturing characterization, royalty pricing for semiconductor and brand IP, regional distribution structures, and the acute interaction with US tariffs and customs valuation.
Profit Split Analysis
7 min
The Profit Split Method Explained
What the profit split method is and the two forms it takes, the indicators that make it most appropriate, the profit to split, and the factors used to divide it.
Asset Management
8 min
Transfer Pricing for Asset Managers: A Sector Deep Dive
A practical examination of transfer pricing for traditional asset managers: management and performance fee allocation, services-based versus profit-split approaches, sub-adviser fee splits, substance requirements, and benchmarking across asset class and strategy.
Value Chain Analysis
8 min
Value Chain Analysis Explained
What a value chain analysis is, how it differs from a supply chain and a functional analysis, and how it tests whether profit aligns with where value is created.
Transfer Pricing and Tax
10 min
Transfer Pricing in the International Tax Architecture
Understand where transfer pricing sits within the broader international tax system: its interaction with CFC regimes, GILTI/NCTI, BEAT, Pillar Two, withholding taxes, and treaty-based dispute resolution mechanisms such as MAP and APA.
Financial Transactions
7 min
Interest Rate Benchmarking for Intercompany Loans: CUP Approaches and Yield Construction
Pricing an intercompany loan with the CUP method: internal versus external comparables and constructing a yield from a risk-free base plus a credit spread.
Financial Transactions
7 min
Credit Rating for Intercompany Loans: Standalone Ratings, Implicit Support, and the Rating Build
Deriving a borrower's credit rating for an intercompany loan: standalone versus group rating, implicit support, and how notching sets the spread.
Financial Transactions
7 min
Debt Capacity and Borrower Analysis: How Much Debt Is Arm's Length?
The quantum question in a loan analysis: assessing a borrower's arm's length borrowing capacity, the metrics that bound it, and how excess debt is treated.
Cashpool
11 min
Pricing & Benchmarking Cash Pool Transactions
Setting arm's length deposit and borrowing rates in a cash pool, rating unrated participants, pricing cross-guarantees, and recharacterizing long-term balances.
TP Methods
8 min
Intercompany Loans: The Arm's Length Framework and Accurate Delineation
The arm's length framework for related-party debt: whether an intragroup loan is debt at all, and the characteristics that govern how it is delineated and priced.
Cashpool
15 min
Cash Pooling 101: Structures, the Pool Leader, and the Synergy Benefit
How groups centralize liquidity through cash pooling, the physical and notional structures, and how the cash pool leader is characterized and paid.
Benchmarking Analysis
14 min
Comparability in Practice: Aggregation and Adjustments
How aggregated comparable data distorts a comparison and invites cherry-picking, and when a comparability adjustment improves reliability rather than adding error.
Benchmarking Analysis
19 min
Selecting the Profit Level Indicator: Margins, Rates of Return, and When Each Distorts
Choosing the profit level indicator: margin versus rate-of-return measures, the turnover identity that shows when a margin distorts, and the fact patterns that decide.
Benchmarking Analysis
11 min
Selecting the Tested Party: A Structured Framework
Choosing the tested party in a one-sided method: the profit-dependence threshold, what disqualifies a candidate, and seven propositions to work through in order.
Benchmarking Analysis
17 minComparability Analysis: The Five Factors and the Economics of an Inference
What comparability actually tests, why the five factors carry different weight across methods, and why comparability is an inference problem, not a checklist.