Articles in Benchmarking Analysis
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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.

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.

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.