Exploring Transfer Pricing Methods Under OECD Guidelines


In the intricate landscape of global business transactions, transfer pricing plays a pivotal role in determining the fair pricing of transactions between related entities. The Organisation for Economic Co-operation and Development (OECD) has formulated comprehensive guidelines to ensure that cross-border transactions are conducted at arm’s length prices, avoiding any undue advantage or disadvantage. This article delves into the transfer pricing methods as outlined by the OECD and their relevance in the realm of corporate taxation.

Traditional Transaction Methods

Under the OECD’s guidance, traditional transaction methods are employed to align controlled transactions with comparable uncontrolled transactions. These methods include:

  1. Comparable Uncontrolled Price Method (CUP): This method draws parallels between prices observed in controlled and uncontrolled transactions, offering a tangible reference point.
  2. Resale Price Method (RPM): Businesses apply this method by deducting the resale margin from the resale price, revealing an appropriate arm’s length price.
  3. Cost Plus Method (CPM): By adding an appropriate profit margin to the costs incurred by the seller, this method establishes pricing congruent with prevailing market norms.
Transactional Profit Methods

Transactional profit methods focus on distributing profits fairly among multiple entities involved in a transaction. They consist of:

  1. Transactional Profit Split Method (TPSM): Designed for transactions with multiple contributors, this method ensures a fair distribution of profits reflective of individual inputs.
  2. Transactional Net Margin Method (TNMM): This approach evaluates profitability by comparing net profit margins against relevant costs, offering insights into the viability of pricing structures.
Selecting the Appropriate Method

Choosing the right transfer pricing method requires a multifaceted approach. Factors such as the availability of information, the strengths and weaknesses of each method, and the appropriateness of the chosen method for the transaction’s nature must be considered. Once a suitable method and reliable comparables are identified, an arm’s length range can be calculated, providing a benchmark for pricing.

Balancing Guidelines and Business Realities

While the OECD-endorsed methods offer a solid foundation for determining transfer prices, it’s essential to note that regulatory frameworks might allow for alternative approaches. However, businesses must ensure that the chosen method is robust and well-documented, meeting the rigorous standards of transfer pricing regulations. Additionally, the method should align with the stipulated requisites under the UAE’s corporate tax law.


Navigating the intricate world of transfer pricing requires a comprehensive understanding of the OECD’s recommended methods and their practical applications. At Alliance Prime, we provide expert guidance on transfer pricing and corporate tax matters, helping businesses make informed decisions that align with both global guidelines and local regulations. To embark on a journey towards effective tax planning, compliance, and strategic growth, reach out to us for a free consultation:

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