Articles in TP Basics
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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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Comparability 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.