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TRANSFER-PRICING4 MIN READ

The method selection deck

Recall when each core transfer-pricing method is likely to be reliable and what trap to avoid.

Direct price When is CUP strongest? When comparable uncontrolled prices exist and material differences in product, terms, volume, market, or timing can be reliably adjusted. CUP can be powerful, but weak comparability creates false precision. Gross vs net Resale price or TNMM for a distributor? Do not pick by entity label alone. Pick by reliable data and comparability. Objection Why not use TNMM for everything? It is easiest to benchmark. A finance lead wants one method across all entities. Your line TNMM is useful for routine entities when net-margin data is reliable, but if direct price or gross-margin evidence is…

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