What is the arm's length principle?

Transfer prices between related parties must equal what unrelated parties would charge. Tax authorities compare intercompany prices to independent market transactions.

What are the main transfer pricing methods?

CUP (Comparable Uncontrolled Price): direct market comparison. Cost-Plus: cost + mark-up. Resale Price: supplier price from reseller perspective. TNMM: compares net margin to comparables. Profit Split: divides combined profit.

What documentation is required?

OECD BEPS requires Master File (global business description), Local File (transaction-level detail), and Country-by-Country Report for MNCs with $750M+ revenue.

Transfer Pricing Arm's Length Calculator

How It Works

Determine the arm's length transfer price range for intercompany transactions using CUP, cost-plus, and TNMM methods. OECD BEPS compliant framework

Each component has a specific meaning:

CUP — The cup recorded for the scenario being assessed.
Cost-plus — The cost-plus recorded for the scenario being assessed.
TNMM methods — The tnmm methods recorded for the scenario being assessed.

Note: Interpret the transfer pricing result against the thresholds and context described above.

How to Use

Enter the CUP, cost-plus, TNMM methods for the scenario you are assessing. Determine the arm's length transfer price range for intercompany transactions using CUP, cost-plus, and TNMM methods. OECD BEPS compliant framework. Use the transfer pricing result to inform your calculation.

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