Sort the method to the fact pattern
Match common transfer-pricing methods to fact patterns where they tend to be reliable.
Match each fact pattern with the method that is usually the strongest starting point. CUP Resale price Cost plus TNMM Profit split Commodity sold to related and unrelated customers under comparable volume and delivery terms Routine buy-sell distributor with reliable third-party gross-margin data Contract R&D support provider with a clean cost base and routine functions Limited-risk distributor with weak product comparability but reliable net-margin public comparables Two affiliates jointly develop and commercialize unique software intangibles Shared-service center provides routine accounting support to group entities Same patented component licensed to an unrelated manufacturer on similar terms Integrated global trading desk where…
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