OECD 2022 Guidelines
Methodologies we apply and defend.
TP Atlas does not pick a method to flatter the result. Each transaction is analysed by the Consultant agent, challenged by the Reviewer, attacked by the Auditor, and arbitrated. The chosen method comes with the alternatives that were considered and why they were rejected.
| Method | Profit Level Indicators | Best fit when… |
|---|---|---|
TNMM Transactional Net Margin Method | Operating margin, Berry Ratio, Markup on costs | Routine functions, no reliable internal/external CUP, comparable financial data available. |
CUP Comparable Uncontrolled Price | Price per unit | Identical or near-identical product/service with public pricing or internal comparable. |
Cost Plus Cost Plus Method | Markup on direct + indirect costs | Routine manufacturing or service provider; tested party performs limited risk activities. |
Resale Minus Resale Price Method | Gross margin on resale | Distributor performs limited functions, no significant value-add. |
Profit Split Profit Split Method | Contribution / Residual split | Highly integrated operations, unique intangibles on both sides, no reliable comparables. |