Skip to main content
Quartyl
Transfer Pricing KnowledgeTransactions & Industries

Transactions & Industries

FAR profiles and benchmarking for distributors, shared services, KPO, manufacturers, R&D, intangibles and intra-group finance.

Transactions & Industries7 Aug 2026

Limited-Risk Distributor: FAR Profile & Benchmarking Guide

Building a defensible FAR profile and TNMM benchmark for a limited-risk distributor in India — functions, risks, PLI choice and the right comparable pool.

Read doc
Transactions & Industries3 Aug 2026

KPO Transfer Pricing in India: A Benchmarking Guide

A practical FAR profile and TNMM benchmarking guide for KPO entities in India — classification, PLI choice and comparability nuances.

Read doc
Transactions & Industries28 Aug 2026

Shared Services TP: Benefit Test, Cost Pools and Allocation Keys

The transfer pricing of shared service centres: the benefit analysis that determines whether a charge is owed, cost pool design, allocation keys that match the benefit, and LVAS marking-up.

Read doc
Transactions & Industries28 Aug 2026

Contract Manufacturing TP: Cost Base, Mark-Up and Capacity Issues

Transfer pricing for contract and toll manufacturers: toll versus contract manufacturing, the cost base line by line, capacity utilization, the TNMM fallback and the audit issues.

Read doc
Transactions & Industries28 Aug 2026

Contract R&D vs Entrepreneurial R&D: DEMPE and Cost-Based Returns

The line between routine contract R&D and entrepreneurial R&D: who performs the DEMPE functions, who controls the risk, who owns the IP, and what each side earns under each characterization.

Read doc
Transactions & Industries28 Aug 2026

Intangibles TP: Licensing, Royalties, DEMPE and HTVI

The transfer pricing of intangibles: the royalty benchmark problem, DEMPE allocation, cost sharing, hard-to-value intangibles, and the Indian practice on royalties.

Read doc
Transactions & Industries28 Aug 2026

Intercompany Loans, Guarantees & Cash Pooling: TP Documentation

The transfer pricing of intra-group finance: the independent-lender test for loans, the genuine-benefit test for guarantees, cash pooling net positions, and the documentation each requires.

Read doc
Transactions & Industries28 Aug 2026

Software and SaaS Transfer Pricing: From Licensing to Profit Splits

The transfer pricing of software and SaaS: the different economics of licensing versus subscriptions, the royalty benchmark problem, DEMPE, and when the profit split is the right answer.

Read doc
Transactions & Industries28 Aug 2026

Group Restructuring TP: Exit Charges, Location Savings and ThinCap

The transfer pricing of group restructurings: the business rationale that has to exist first, exit charges, the apportionment of location savings, thin capitalization, and the documentation sequence.

Read doc
Transactions & Industries28 Aug 2026

Intercompany Agreements: Legal Form Aligned with Economic Substance

The clauses that carry the transfer pricing file: scope, IP ownership, pricing mechanics, term and termination — and why the agreement must match the actual conduct, not just describe it.

Read doc

Go from guide to finished study

Quartyl applies the method, PLI and screening steps above automatically — with documented reasons for every exclusion.

Book a Demo

Tell us what you'd like benchmarked

We'll confirm a 30-minute screen-share slot within one business day.

We reply within one business day. Your details are used only to arrange the demo — never shared or sold.