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A legal structure where a parent company owns enough of the controlling share of a company in a different country, which can affect transfer pricing outcomes.

A transfer pricing method where a standard markup is applied to the costs of producing goods or services to determine the transfer price.

A transfer pricing method that compares the price charged for property or services in a controlled transaction to the price charged in a comparable uncontrolled transaction.

An analysis conducted to understand the functions performed, assets used, and risks assumed by parties in intercompany transactions.

The price at which divisions of a company transact with each other for goods, services, or use of property.

Compares the net profit margin of a taxpayer arising from a non-arm's length transaction with the net margins that would have been realized if the transaction had been conducted at arm's length.

An agreement between a taxpayer and a tax authority defining an appropriate set of criteria for the determination of the transfer pricing for future transactions over a fixed period of time.

A transfer pricing method that determines the price based on the price at which an item is resold to an independent party, minus an appropriate gross margin.

Strategies used by multinational companies to exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations.

The methods used to value intangible property such as patents, trademarks, or intellectual property for transfer pricing purposes.

The condition that the transfer price should be the same as if the divisions were two independent entities, acting in their own interest.

Determines the division of profits that independent enterprises would have expected to realize from engaging in the transaction or series of transactions.

Occurs when the same income is taxed by two or more countries because transfer pricing adjustments made by one country are not accepted by another.

Documentation that substantiates a company's compliance with applicable laws and regulations concerning transfer pricing.

A fixed place of business through which a business's activities are wholly or partly carried on, impacting the way profits are allocated and taxed.

One of the elements of transfer pricing documentation that provides an overview of the multinational enterprise’s global business operations and transfer pricing policies.

Determines which party in an intercompany transaction assumes the financial risks and how that impacts the transfer price.