Transfer Pricing Methods
Compare CUP, resale price, cost plus, TNMM, CPM, and profit split with method-selection frameworks, formulas, and worked examples.
- OECD Methods
- 5
- Method Guides
- 12
- OECD and US Context
- OECD and US Context
Transfer Pricing Methods: The Complete Guide (2026)
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.
Method Deep-Dives
Use these guides to select, apply, compare, and document transfer pricing methods for common fact patterns.
- 18 min
CUP Method Guide
Internal vs external CUPs, comparability thresholds, adjustments, and examples.
- 27 min
Resale Price Method
When RPM fits distributor fact patterns and how gross margin issues affect reliability.
- 20 min
Cost Plus Method
Cost base, mark-up logic, tested party profile, comparability issues, and mistakes.
- 18 min
CPM vs TNMM
How US CPM and OECD TNMM compare in practical benchmarking work.
- 15 min
Profit Split Method
When one-sided methods fail and combined profit allocation becomes more appropriate.
- 20 min
How to Choose a Method
A decision framework based on comparability, data availability, and tested-party logic.
- 16 min
Methods with Examples
Worked examples for CUP, RPM, cost plus, TNMM, and profit split.
- 15 min
Transfer Pricing Formula
Why there is no single universal formula and how calculations differ by method.
- 11 min
Cost Plus vs TNMM
When gross mark-up testing is preferable and when net margin testing is safer.
- 10 min
CUP vs TNMM
When direct price evidence beats profit-margin benchmarking.
- 12 min
Profit Split vs TNMM
How to choose between a one-sided net margin method and a two-sided profit split.
- 13 min
Internal vs Tax Transfer Pricing
Why management accounting transfer prices differ from tax-compliant arm's length prices.
Method Terms
Definitions that support method selection and benchmarking analysis.
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