The Three Types of Transfer Pricing

Understanding and applying the correct transfer pricing methods in the globalised economy is crucial for maintaining regulatory compliance and achieving optimal intercompany transaction strategies. This guide explores the core transfer pricing methods, offering insights tailored to tax professionals, accountants, lawyers, and executives in multinational and medium-sized enterprises.

What is Transfer Pricing?

Transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because these transactions can significantly affect corporate tax liabilities and financial performance, adhering to international guidelines is strategic and mandatory.

1. Cost-Based Transfer Pricing

Cost-based transfer pricing involves setting prices based on the costs incurred to produce goods or services, plus a markup that ensures profitability.

Key Points:

  • Straightforward to implement.
  • Ensures cost recovery and a basic profit margin.
  • Best suited for transactions involving standardized products.


  • Does not reflect market conditions or changes in demand.
  • Risk of misalignment with the arm’s length principle if not properly benchmarked.

2. Market-Based Transfer Pricing

Market-based transfer pricing aligns prices with those in the open market for comparable goods and services. It adheres closely to the arm’s length principle, aiming to mimic the conditions of transactions between unrelated parties.

Key Points:

  • Reflects fair market value.
  • Reduces risk of legal or tax authority challenges.
  • Useful in competitive, transparent markets.


  • Requires robust market data, which may not be available for unique or niche products.
  • Potentially volatile and can fluctuate with market conditions.

3. Transactional Net Margin Method (TNMM)

The Transactional Net Margin Method examines the net profit margin from a transaction achieved by entities involved, compared to similar transactions by independent companies.

Key Points:

  • Flexible and applicable across a wide range of scenarios.
  • Focuses on profitability, which can be aligned more easily across different markets.


  • More complex to implement and justify.
  • Requires detailed financial data for comparison.

Advanced Transfer Pricing Techniques

Beyond the basic methods, multinational companies often utilize more sophisticated strategies to refine their transfer pricing practices, such as profit split methods and advanced pricing agreements (APAs). These techniques require deep understanding and strategic planning to be implemented effectively.

Importance of Expert Guidance

Transfer pricing is inherently complex, with significant repercussions for mismanagement. Misaligned transfer pricing can lead to hefty penalties, double taxation, and damage to a company’s reputation.

Why Partner with TRM?

Transfer pricing poses unique challenges that require specialized knowledge and strategic foresight. TRM offers expert consultation to navigate these waters, ensuring compliance while optimizing business processes. Their professionals are equipped to tailor transfer pricing strategies that align with company goals and regulatory demands.


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