Methods & PLIs
CUP, RPM, Cost Plus, Gross Margin, TNMM, CPM and Profit Split — formulas, PLI selection and worked practical examples.
Transfer Pricing Methods: A Practical Guide
A practical comparison of CUP, RPM, Cost Plus, TNMM and Profit Split methods — and how to choose the right one for your Indian TP benchmarking study.
Read docTNMM in India: How to Select the Right PLI
How to select the right Profit Level Indicator (PLI) for TNMM benchmarking in India — PLI options, decision rules and a worked OP/OC example.
Read docCUP Method: Complete Guide with Worked Examples (2026)
The Comparable Uncontrolled Price method end to end — internal vs external CUPs, comparability thresholds, commodity pricing, adjustments, a worked example and common mistakes.
Read docCost Plus Method: Cost Base, Mark-Up and Common Mistakes (2026)
The cost plus method for Indian transfer pricing — building the cost base, what belongs in it, mark-up logic, the tested party profile, comparability issues and a worked example.
Read docGross Margin Method in India: The Underused Alternative to TNMM
The Gross Margin Method under Indian transfer pricing rules — when GMM beats TNMM, denominator discipline, how TPOs treat it, and a worked example with gross margin on sales.
Read docResale Price Method (RPM): When It Fits and When It Fails
The Resale Price Method (RPM) explained: how the gross margin of comparable resellers sets the arm’s length purchase price, with a worked example and where it fails.
Read docComparable Profits Method (CPM): US Rules, PLIs and Practice
The Comparable Profits Method (CPM) under US Section 1.482-5: the one-sided testing discipline, the six regulatory PLIs, and where CPM fits in Indian practice under Rule 10B.
Read docProfit Split Method: When One-Sided Methods Break Down
The Profit Split Method for transactions where both parties are non-routine: conventional and residual splits, HTVI handling, a worked example and India practice.
Read docHow to Choose a Transfer Pricing Method: The Decision Framework (2026)
A step-by-step framework for transfer pricing method selection in India — comparability first, data second, tested party logic third — with the decision tree and documentation of the choice.
Read docAmount B for Limited-Risk Distributors: OECD Ranges and Caveats
Amount B: the OECD’s standardized 0.7–1.5% of net-cost routine return for limited-risk distributors and service providers — the conditions, the caveats, and its position in India.
Read docCUP vs TNMM: When Direct Price Evidence Beats Margin Benchmarking
CUP vs TNMM side by side: when a direct uncontrolled price beats margin benchmarking, a worked comparison on the same fact pattern, and the fallback when no genuine CUP exists.
Read docCost Plus vs TNMM: Gross Mark-Up vs Net Margin Testing
Cost Plus and TNMM both use the cost base, but they answer different questions. The mechanics of each, the risk profile of each, and the documentation that survives audit.
Read docCPM vs TNMM: US and OECD Methods Compared
CPM and TNMM compared: regulatory lineage, the PLI differences, the transaction-versus-company comparison, and what the difference means when you actually run the benchmark.
Read docProfit Split vs TNMM: One-Sided vs Two-Sided Approaches
Profit Split vs TNMM: when both parties are non-routine, why one-sided margin testing fails, the comparability burden, and how Indian TPOs respond to a split argument.
Read docProfit Level Indicators (PLI) Reference: Every Formula, Every Use
Every Profit Level Indicator in one table: Operating Margin, OP/OC, Net Cost Plus, Gross Margin, Berry Ratio, ROA and ROCE — formulas, denominators, best fits and pitfalls.
Read docIs There a Transfer Pricing Formula? No — Here's the Math
There is no single transfer pricing formula. Here is the math that actually exists: the per-method calculations, the working capital adjustment layer, and the range statistics.
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Go from guide to finished study
Quartyl applies the method, PLI and screening steps above automatically — with documented reasons for every exclusion.