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Homework answers / question archive / Describe the five specific methods used to determine the arm's length prices in international transfer pricing for the sale of tangible property, discussing the situations in which each method might be most appropriate

Describe the five specific methods used to determine the arm's length prices in international transfer pricing for the sale of tangible property, discussing the situations in which each method might be most appropriate

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Describe the five specific methods used to determine the arm's length prices in international transfer pricing for the sale of tangible property, discussing the situations in which each method might be most appropriate.

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The five specific methods used to determine arm's length prices can be divided into two groups: traditional methods and transactional methods of determination. Following are the five methods in detail:

Traditional Methods

  • Comparable Uncontrolled Price - The comparable uncontrolled price method uses a contrasting method to analyze the actual cost of goods or services in a controlled activity to the cost charged for goods or services in an uncontrolled activity in a relatable situation.
  • Cost Plus - The cost plus approach determines what the actual cost of a good or service is and then what an appropriate additional charge for the good or service would be in a comparable transaction.
  • Resale Price - The resale price method uses a similar sales company to complete marketing and selling functions as a way to test the transaction. This offers an expert opinion on the transaction.

Transactional Methods

  • Transactional Net Margin Method -- this method completes a juxtaposition of the net profit margin that is achieved in a group of controlled transactions to a group of comparable uncontrolled contracts.
  • Profit Split Method - the profit split method is used in a joint venture relationship that includes both parts of the controlled transaction that are relevant to intangible properties.