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Compare CUP, resale price, cost plus, TNMM, CPM, and profit split with method-selection frameworks, formulas, and worked examples.
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Use this as the main reference before diving into topic-specific guides.
A practitioner-focused tour of OECD transfer pricing methods—CUP, RPM, cost plus, TNMM, and profit split—with Amount B, functional analysis, and how to document method selection defensibly.
Read the complete guideDeep dives
Use these guides to select, apply, compare, and document transfer pricing methods for common fact patterns.
CUP Method Guide
Internal vs external CUPs, comparability thresholds, adjustments, and examples.
Resale Price Method
When RPM fits distributor fact patterns and how gross margin issues affect reliability.
Cost Plus Method
Cost base, mark-up logic, tested party profile, comparability issues, and mistakes.
CPM vs TNMM
How US CPM and OECD TNMM compare in practical benchmarking work.
Profit Split Method
When one-sided methods fail and combined profit allocation becomes more appropriate.
How to Choose a Method
A decision framework based on comparability, data availability, and tested-party logic.
Methods with Examples
Worked examples for CUP, RPM, cost plus, TNMM, and profit split.
Transfer Pricing Formula
Why there is no single universal formula and how calculations differ by method.
Cost Plus vs TNMM
When gross mark-up testing is preferable and when net margin testing is safer.
CUP vs TNMM
When direct price evidence beats profit-margin benchmarking.
Profit Split vs TNMM
How to choose between a one-sided net margin method and a two-sided profit split.
Internal vs Tax Transfer Pricing
Why management accounting transfer prices differ from tax-compliant arm's length prices.
Glossary
Definitions that support method selection and benchmarking analysis.
AI Benchmarks helps teams apply consistent comparable review, rationale, and range analysis once the method and tested party are selected.