55 min webinar
Hard Questions in TNMM Benchmarking
Functional analysis, search design, and comparable selection: a practical webinar on the hard questions that decide whether a TNMM benchmark can survive review.
Borys Ulanenko · Sven van der Heide
Resources
Transfer Pricing Resources
Expert articles, practical tools, and downloads for benchmarking, documentation, and tax operations.
Start with the right workstream
Use these hubs for structured guidance across your most common transfer pricing tasks.
- Poland Transfer Pricing HubPLPolish-language guidance on Local File, TPR, deadlines, comparable-company searches, PKD 2025, and profitability indicators.
- Benchmarking HubMaster screening logic, tested-party selection, PLI choice, and comparability adjustments with practical guides.
- Documentation HubNavigate Master File, Local File, CbCR, intercompany agreements, and audit-defense fundamentals.
- Pillar Two & CbCR HubTrack GloBE requirements, minimum-tax mechanics, and CbCR implementation with practical guides.
- Transfer Pricing Methods HubCompare CUP, RPM, cost plus, TNMM, CPM, profit split, formulas, and worked examples.
Choose the workflow you want to improve
Compare benchmarking, documentation, and broader automation workflows, including where AI helps and where practitioner review remains essential.
- Transfer Pricing SoftwareHow ArmsLength AI fits benchmarking, documentation, audit trail, and review workflows.
- Benchmarking SoftwareAI-supported comparable screening, evidence capture, accept/reject rationale, and report exports.
- Documentation SoftwareMaster File and Local File roll-forward, fact review, AI-assisted drafting, and approval workflows.
- Transfer Pricing AutomationWhere automation helps TP teams without replacing practitioner judgment.
- AI in Transfer PricingPractical AI use cases, controls, source evidence, audit trails, and governance.
Common transfer pricing fact patterns
Use these guides when the question starts with the business model rather than the method.
- Distributor Transfer PricingRoutine distributors, limited-risk distributors, RPM vs TNMM, Amount B caveats, and benchmarking.
- Shared Services Transfer PricingBenefit test, cost pools, allocation keys, LVAS, markups, and service-charge documentation.
- Contract Manufacturer Transfer PricingContract and toll manufacturing, cost plus vs TNMM, cost-base design, and capacity issues.
- Software and IP Transfer PricingSoftware licensing, SaaS models, DEMPE, royalties, profit split, HTVI, and cost sharing.
- Contract R&D Transfer PricingRoutine R&D services, DEMPE, risk control, cost-based returns, and IP ownership issues.
Free tools for day-to-day transfer pricing work
- OECD Transfer Pricing GuidelinesSearchable text with paragraph-level references for daily arm's length analysis.Browse guidelines
- AI NACE Code CreatorGenerate relevant NACE codes from business descriptions and speed up initial setup.Try tool
- TP Questionnaire GeneratorCreate focused questionnaires for interviews and fact collection.Try tool
- Transfer Pricing GlossaryReference core terms and definitions used across benchmarking and documentation projects.Browse glossary
Recent sessions
Watch practical walkthroughs and implementation discussions from the team.
45 min webinar
Benchmarking 2.0: What We Learned After Analyzing 1.5 Million Comparables
A deep dive into modern transfer pricing benchmarking workflows, backed by data from 1.5M+ comparables and our global practitioner survey. See how AI is transforming comparability analysis in 2025.
Borys Ulanenko · Sven van der Heide
All resource articles
LatestMethods18 min read
Contract Manufacturer Transfer Pricing: Cost Plus, TNMM, and Audit Issues (2026)
How to price contract and toll manufacturing arrangements: tested party selection, cost plus vs TNMM, cost-base design, capacity utilization, inventory and warranty risk, benchmarking, documentation, and audit issues.
Borys Ulanenko
Methods18 min read
Contract R&D Transfer Pricing: Cost Plus, DEMPE, and Risk Control (2026)
How to price contract R&D arrangements: distinguishing routine research services from entrepreneurial IP development, DEMPE and risk control, cost plus vs TNMM, cost-base and mark-up issues, tax/accounting caveats, documentation, audit issues, and examples.
Methods11 min read
Cost Plus vs TNMM: Gross Mark-Up Method vs Net Margin Method
Cost plus and TNMM can both use costs as a reference point, but they are not the same transfer pricing method. This guide explains gross mark-up vs net cost plus, when each method fits, examples, audit risks, and documentation points.
Methods18 min read
CUP Method in Transfer Pricing: Complete Guide with Examples (2026)
A practical guide to the Comparable Uncontrolled Price method: internal vs external CUPs, comparability thresholds, commodity pricing, adjustments, worked examples, common mistakes, and documentation points.
Methods10 min read
CUP vs TNMM: Direct Price Method vs Net Margin Method
CUP compares controlled and uncontrolled transaction prices directly, while TNMM tests net profitability. This guide explains when CUP is stronger, when TNMM is more practical, and how to document the choice.
Methods18 min read
Distributor Transfer Pricing: Routine, Limited-Risk, RPM, TNMM and Amount B (2026)
A practitioner guide to distributor transfer pricing: routine and limited-risk distributors, buy-sell models, RPM vs TNMM, Amount B caveats, benchmarking, documentation, audit issues, and a worked example.
Methods20 min read
How to Choose the Best Transfer Pricing Method (2026)
A practical framework for choosing the most appropriate transfer pricing method using transaction delineation, comparability, data availability, tested-party logic, one-sided vs two-sided methods, and jurisdiction-specific caveats.
7 of 66
Featured downloads
Templates and checklists your team can use immediately.
pdf · checklist
Transfer Pricing Benchmarking Filters
Essential benchmarking filters for transfer pricing studies, helping you create more accurate and defensible comparable searches.
pdf · guide
Transfer Pricing Profit Level Indicators (PLIs)
Comprehensive overview of common Profit Level Indicators used in transfer pricing analyses, with guidance on selecting the most appropriate PLI for your situation.
pdf · checklist
Local File Review Checklist
Essential checklist for reviewing local file documentation, ensuring it meets all compliance requirements and effectively supports your transfer pricing positions.
pdf · infographic
Benchmark Cheatsheet
Quick reference guide for transfer pricing benchmarking with tips and best practices for creating robust comparable searches.
Need help finding the right starting point?
Tell us your current transfer pricing task and we will point you to the right hub, guide, or template.