Which transfer pricing method is most commonly accepted by tax authorities?

The Comparable Uncontrolled Price (CUP) method is preferred when identical or nearly identical comparables exist (commodities, financial transactions). For services and IP, the TNMM (Transactional Net Margin Method) comparing operating margins to independent benchmarks is most widely used globally.

What documentation is required under OECD BEPS Action 13?

BEPS Action 13 requires three-tier documentation: Master File (global business overview), Local File (entity-specific transactions), and Country-by-Country Report (for MNEs above EUR 750 million consolidated revenue). Local Files must demonstrate economic substance and arm's length pricing for each material transaction.

Transfer Pricing Arm's Length Comparable

Determine arm's length transfer prices for intercompany transactions using the Comparable Uncontrolled Price (CUP), Resale Price, Cost Plus, TNMM, or Profit Split methods per OECD Guidelines.

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Frequently Asked Questions

Which transfer pricing method is most commonly accepted by tax authorities?

What documentation is required under OECD BEPS Action 13?