The Berry Ratio is a profit-level indicator that divides gross profit by operating expenses:
text
Berry Ratio = Gross Profit ÷ Operating Expenses
A result of 1.20 means the tested business earns €1.20 of gross profit for each €1.00 of operating expense. Because gross profit equals operating expenses plus operating profit, a ratio of 1.00 represents operating break-even when the accounting classifications are consistent.
When it can be reliable
The OECD Transfer Pricing Guidelines discuss Berry ratios in paragraphs 2.106–2.108. Paragraph 2.107 identifies three conditions that should be supported by the facts:
the value of the functions performed is proportional to operating expenses;
that value is not materially affected by the value of the products handled; and
the tested business does not perform another significant function, such as manufacturing, that should be remunerated using another method or indicator.
The ratio can therefore be useful for a genuine intermediary whose operating expenses reflect its value-adding activity and whose product costs largely pass through. It is not automatically appropriate for every distributor or sales agent.
Berry ratios are highly sensitive to whether costs are classified as cost of goods sold or operating expenses. Use consistent accounting classifications for the tested party and comparables, and reconcile any material differences before interpreting a range.
Short example
Item
Amount
Revenue
€15,000,000
Cost of goods sold
€14,200,000
Gross profit
€800,000
Operating expenses
€650,000
Operating profit
€150,000
text
Berry Ratio = €800,000 ÷ €650,000 = 1.23
The calculation alone does not establish an arm's-length result. The functional analysis, accounting consistency, comparable search and resulting range still need to support the conclusion.