What is profit split method?
A method that identifies the relevant profits to be split for of associated enterprises from a controlled transaction and then splits those profits between the associated enterprises on an economically valid basis that approximates the division of profits that would have been agreed at arm’s length.”
What is CPM in transfer pricing?
The Comparable Profits Method (“CPM”) is a common method for establishing an amount charged in a controlled transaction based on objective measures of profitability. The CPM is a specified transfer pricing method that compares the Taxpayer’s operating results with those of uncontrolled taxpayers.
What is the resale price method?
The resale price method is generally most appropriate where the final transaction is with an independent distributor. The starting point in the resale price method is the price at which a product that has been purchased from an associated enterprise is then resold to an independent enterprise.
What are the 5 methods of transfer pricing?
Here are five widely used transfer pricing methods your business should consider.
- Comparable Uncontrolled Price.
- Cost-Plus.
- Resale-Minus.
- Transactional Net Margin (TNMM)
- Profit Split.
What is the cut method?
Comparable Uncontrolled Transaction (CUT) Method is a transfer pricing methodology used in the US. It determines an arm’s length royalty rate for an intangible by reference to uncontrolled transfers of comparable intangible property under comparable circumstances.
What does TNMM stand for?
Transactional Net Margin Method (TNMM) is a transactional profit method that compares the net profit earned by a tested party of a controlled transaction with the net profit earned in uncontrolled transactions.
What are the four transfer pricing methods?
There are five main OECD methods for transfer pricing: CUP, Cost Plus, Resale Price, TNMM and the Profit Split Method. Taxpayers must apply the ‘most appropriate’ method for their particular case. There is no longer an overt hierarchy of methods, but where a ‘CUP’ exists it should be used.