Knowledge Base Help Center
< All Topics
Print

Cost Plus Method in Transfer Pricing

What is Cost Plus Method in Transfer Pricing?

Cost plus method in transfer pricing calculates an arm’s length price by adding an appropriate gross markup to a related-party supplier’s costs. It compares the supplier’s cost base—direct and indirect production or service costs—and applies a profit margin benchmarked from comparable independent transactions. This method suits intercompany manufacturing or service arrangements where reliable comparable gross markups exist, ensuring intra-group prices align with market norms. Adjustments may be required for differences in functions, assets or risk profiles.

A Comprehensive Guide on Cost Plus Method

The cost plus method represents one of the most fundamental and widely-applied transfer pricing methodologies in international taxation, serving as a cornerstone for determining arm’s length prices between related entities within multinational enterprises. This traditional transaction method has evolved significantly since its initial codification in the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines, becoming an essential tool for tax authorities and practitioners worldwide in ensuring compliance with the arm’s length principle 1.

The cost plus method operates on the fundamental principle that entities engaged in controlled transactions should receive compensation that reflects the costs incurred in producing goods or providing services, enhanced by an appropriate profit margin that independent parties would negotiate under similar circumstances 2. This methodology has gained particular prominence in contemporary transfer pricing practice due to its practical applicability across diverse industries and transaction types, ranging from manufacturing operations to service provision arrangements 3.

Understanding the Cost Plus Method in Transfer Pricing

Definition and Core Principles of the Cost Plus Method

The cost plus method constitutes a traditional transaction method that determines transfer prices by adding an appropriate markup to the costs incurred by the supplier of goods or services in controlled transactions 4. This approach fundamentally differs from market-based pricing methods by focusing on the cost structure of the tested party rather than external market prices 5.

The theoretical foundation of the cost plus method rests upon the assumption that independent enterprises seek to recover their costs while achieving a reasonable profit margin commensurate with the functions performed, risks assumed, and assets utilized in the transaction 6. This principle aligns with fundamental economic theory regarding competitive markets, where entities must cover their production costs and generate sufficient returns to sustain operations and attract investment 7.

The cost plus method’s prominence in transfer pricing practice stems from its alignment with the arm’s length principle, which requires that controlled transactions reflect terms and conditions that independent parties would establish under comparable circumstances 8. This alignment ensures that multinational enterprises cannot artificially manipulate transfer prices to shift profits to low-tax jurisdictions, thereby preserving the integrity of national tax bases 9.

Historical Development and Evolution of the Cost Plus Method

The cost plus method’s evolution reflects the broader development of international transfer pricing frameworks, beginning with early bilateral tax treaties and progressing through multilateral initiatives led by the OECD 10. The method gained formal recognition in the 1979 OECD Transfer Pricing Guidelines and has undergone continuous refinement through subsequent revisions, particularly following the Base Erosion and Profit Shifting (BEPS) project 11.

The post-BEPS environment has witnessed significant enhancements to the cost plus method’s application, particularly regarding the treatment of intangibles, risk allocation, and documentation requirements 12. These developments reflect the increasing sophistication of global business models and the corresponding need for transfer pricing methods that accurately capture economic substance 13.

How the Cost Plus Method Works in Practice

Fundamental Mechanics of Cost Plus Method Application

The cost plus method operates through a systematic process that begins with the identification and quantification of all relevant costs incurred by the supplier in producing goods or providing services 14. This cost base typically encompasses both direct costs, such as raw materials and labor, and indirect costs, including overhead expenses that can be reasonably attributed to the controlled transaction 15.

The determination of an appropriate markup constitutes the second critical component of cost plus method application, requiring extensive benchmarking studies to identify profit margins earned by independent entities performing similar functions under comparable circumstances 16. This benchmarking process involves analyzing financial data from public databases to establish arm’s length markup ranges that reflect market conditions and competitive dynamics 17.

Cost Plus Method Formula and Calculation Framework

The basic cost plus method formula can be expressed as: Transfer Price = Cost Base + (Cost Base × Appropriate Markup Percentage) 18. This straightforward mathematical relationship masks considerable complexity in determining both the appropriate cost base and markup percentage 19.

The cost base determination requires careful consideration of cost accounting principles and the specific nature of the controlled transaction 20. Direct costs typically include materials, labor, and other expenses directly attributable to the production process, while indirect costs encompass overhead allocations based on reasonable and consistent methodologies 21.

The markup calculation presents additional complexities, as it must reflect the profit that independent entities would earn for performing similar functions while assuming comparable risks and utilizing similar assets 22. This requirement necessitates comprehensive functional analyses and detailed comparability studies to ensure that the selected markup accurately reflects arm’s length conditions 23.

When to Use the Cost Plus Method

Optimal Scenarios for Cost Plus Method Application

The cost plus method proves most effective in transactions involving routine manufacturing or service provision activities where the tested party maintains a relatively simple functional profile with limited risk exposure 24. Manufacturing scenarios particularly well-suited for cost plus method application include contract manufacturing arrangements, toll manufacturing operations, and the production of semi-finished goods for further processing by related entities 25.

Service transactions represent another primary area of cost plus method application, particularly for shared services centers, administrative support functions, and routine technical services 26. The OECD’s guidance on low-value-adding services explicitly endorses a simplified cost plus approach with standardized markups for qualifying administrative, technical, and other support services 27.

The availability of detailed cost data constitutes a critical prerequisite for effective cost plus method application, as the methodology’s reliability depends fundamentally on the accuracy and completeness of cost information 28. Organizations with sophisticated cost accounting systems and established cost allocation methodologies typically find the cost plus method more practical and defensible than entities with limited cost tracking capabilities 29.

Inappropriate Applications of the Cost Plus Method

The cost plus method proves less suitable for transactions involving entities that perform complex functions, assume significant risks, or utilize valuable intangible assets 30. Distribution activities, particularly those involving marketing intangibles or significant market risks, typically require alternative methodologies such as the resale price method or transactional net margin method 31.

Research and development activities present particular challenges for cost plus method application, as the methodology may fail to adequately capture the value created through innovative activities or the risks associated with uncertain outcomes 32. Similarly, transactions involving unique intangibles or highly integrated business operations may require profit split methodologies that better reflect the contributions of multiple parties 33.

Cost Plus Method Documentation and Compliance Requirements

Essential Documentation Elements for Cost Plus Method

Comprehensive documentation constitutes a fundamental requirement for successful cost plus method implementation and defense during tax examinations 34. This documentation must demonstrate the appropriateness of cost base determination, markup selection, and overall compliance with the arm’s length principle through detailed economic analyses and supporting evidence 35.

Cost base documentation requires detailed breakdowns of all direct and indirect costs included in the calculation, supported by underlying accounting records and cost allocation methodologies 36. Organizations must maintain clear audit trails demonstrating how costs were identified, classified, and allocated to specific transactions or business units 37.

Benchmarking documentation represents another critical component, requiring comprehensive search strategies, database selections, and rejection criteria for potential comparables 38. This documentation must demonstrate that selected comparables perform similar functions, assume comparable risks, and operate under similar economic circumstances as the tested party 39.

Regulatory Compliance and Audit Defense

Tax authorities worldwide have intensified their scrutiny of transfer pricing arrangements, requiring organizations to maintain robust documentation and prepare for increasingly sophisticated audit procedures 40. Successful audit defense requires proactive documentation maintenance, regular benchmarking updates, and comprehensive transfer pricing policies that demonstrate ongoing compliance with evolving regulations 41.

The digital transformation of business operations has created new documentation challenges and opportunities, requiring organizations to adapt their cost plus method applications to accommodate digital assets, cloud computing costs, and other technological considerations 42. These developments necessitate enhanced documentation practices and more sophisticated economic analyses to demonstrate compliance with traditional transfer pricing principles in digital business models 43.

Industry-Specific Applications of the Cost Plus Method

Manufacturing Sector Applications

The manufacturing industry represents the most traditional and extensively documented application area for the cost plus method, encompassing diverse subsectors from automotive components to pharmaceutical manufacturing 44. Contract manufacturing arrangements, where related entities produce goods under specific agreements without assuming market or inventory risks, exemplify ideal cost plus method applications due to their limited risk profiles and routine operational characteristics 45.

Electronics and technology manufacturing present unique considerations for cost plus method application, particularly regarding the treatment of rapidly depreciating assets and the allocation of research and development costs 46. Organizations in these sectors must carefully consider the appropriate treatment of intellectual property costs and ensure that markup determinations reflect the technological sophistication and competitive dynamics of their specific market segments 47.

Service Industry Implementations

Service industries have embraced the cost plus method extensively, particularly for shared services centers and routine administrative functions that support multiple group entities 48. Information technology services, human resources support, and financial management functions frequently utilize cost plus methodologies due to their standardized nature and measurable cost structures 49.

Professional services present more complex considerations for cost plus method application, as these activities often involve specialized expertise and client-specific solutions that may justify higher markup levels 50. Legal services, consulting activities, and technical advisory functions require careful functional analysis to determine whether their complexity and risk profiles align with cost plus method assumptions 51.

Cost Plus Method Challenges and Limitations

Practical Implementation Challenges

The cost plus method faces significant practical challenges in contemporary business environments, particularly regarding cost allocation methodologies and the identification of appropriate benchmarking data 52. Organizations operating integrated business models often struggle to isolate costs attributable to specific transactions or entities, requiring sophisticated cost accounting systems and allocation methodologies 53.

Benchmarking challenges represent another significant limitation, as the availability of comparable markup data varies substantially across industries and geographic regions 54. The cost plus method’s reliance on external benchmarking data creates dependencies on commercial databases and statistical methodologies that may not adequately capture the specific characteristics of particular transactions or industries 55.

Theoretical and Methodological Limitations

The cost plus method’s theoretical foundations assume relatively stable cost structures and predictable market conditions that may not reflect contemporary business realities 56. Digital transformation, supply chain volatility, and evolving business models challenge traditional cost-plus assumptions and require enhanced analytical approaches to maintain arm’s length compliance 57.

The method’s focus on cost recovery may inadequately capture value creation in knowledge-intensive industries or transactions involving significant intangible assets 58. Organizations operating in high-value, innovation-driven sectors may find that cost plus methodologies systematically undervalue their contributions and fail to reflect the economic substance of their activities 59.

Best Practices for Cost Plus Method Implementation

Strategic Planning and Method Selection

Successful cost plus method implementation requires comprehensive strategic planning that aligns method selection with business operations, risk profiles, and regulatory environments 60. Organizations should conduct thorough functional analyses to ensure that cost plus applications accurately reflect the economic characteristics of their controlled transactions and the relative contributions of participating entities 61.

Regular benchmarking updates and market analyses ensure that cost plus method applications remain current and defensible throughout changing economic conditions 62. Organizations should establish systematic review processes that evaluate markup appropriateness, cost allocation methodologies, and overall compliance with evolving transfer pricing standards 63.

Documentation and Risk Management

Proactive documentation strategies represent critical success factors for cost plus method implementation, requiring organizations to maintain comprehensive records that demonstrate compliance with the arm’s length principle 64. These documentation practices should encompass detailed cost tracking systems, robust benchmarking methodologies, and clear audit trails that support transfer pricing positions during regulatory examinations 65.

Risk management frameworks should address potential challenges including cost allocation disputes, benchmarking data limitations, and evolving regulatory requirements 66. Organizations should develop contingency plans for addressing cost plus method limitations and establish alternative methodologies for transactions that may not be suitable for traditional cost plus applications 67.

Future Developments and Emerging Trends

Technology Integration and Digital Transformation

The integration of advanced technologies including artificial intelligence, machine learning, and automated data analytics presents significant opportunities for enhancing cost plus method application and compliance 68. These technological developments enable more sophisticated cost tracking, real-time benchmarking updates, and enhanced documentation capabilities that support robust transfer pricing compliance programs 69.

Digital business models and cloud-based operations require enhanced analytical approaches that address the unique characteristics of digital assets and services while maintaining compliance with traditional cost plus method principles 70. Organizations must adapt their cost plus method applications to accommodate evolving business models while preserving the fundamental economic principles underlying arm’s length pricing 71.

The cost plus method remains a fundamental pillar of international transfer pricing practice, providing a practical and theoretically sound approach for determining arm’s length prices in appropriate circumstances. While the method faces challenges from evolving business models and technological developments, its core principles continue to offer valuable frameworks for ensuring compliance with the arm’s length principle. Success in cost plus method implementation requires careful attention to functional analysis, comprehensive benchmarking, robust documentation, and proactive adaptation to changing regulatory and business environments. Organizations that invest in sophisticated cost plus method applications while maintaining flexibility for alternative approaches position themselves for sustainable transfer pricing compliance in an increasingly complex global economy.

  1. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, https://www.oecd.org/content/dam/oecd/en/publications/reports/2022/01/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-2022_57104b3a/0e655865-en.pdf
  2. Academy of Tax Law, Cost-Plus Method Definition, 2024, https://academyoftaxlaw.com/glossary/cost-plus-method-definition/
  3. Valentiam Group, The Cost Plus Transfer Pricing Method, February 11, 2021, https://www.valentiam.com/newsandinsights/cost-plus-method
  4. HMRC International Manual, Transfer Pricing Methodologies: OECD Guidelines Cost Plus, January 28, 2025, https://www.gov.uk/hmrc-internal-manuals/international-manual/intm421060
  5. BDO Malta, Transfer Pricing Methods, https://www.bdo.com.mt/en-gb/services/tax/transfer-pricing/transfer-pricing-methods
  6. Tax Risk Management, The Cost Plus Method in Transfer Pricing, https://www.taxriskmanagement.com/cost-plus-method-transfer-pricing/
  7. Academy of Tax Law, The Cost Plus Method in Transfer Pricing, July 8, 2024, https://academyoftaxlaw.com/cost-plus-method-transfer-pricing/
  8. Economic Space – Digital Economy – Finance – Management, Tax Regulation of Transfer Pricing and Its Impact on International Business, January 1, 2024, https://eco-science.net/wp-content/uploads/2024/01/1.24._topic_Nataliia-F.-Stebliuk-Daniil-K.-Myronenko-Rostislav-G.-Botvinov-98-108.pdf
  9. International Journal of Community Service and Academic Research, Analysis of the Most Suitable Transfer Pricing Method in Making Corresponding Adjustments, May 30, 2025, https://jrssem.publikasiindonesia.id/index.php/jrssem/article/view/829
  10. IBFD, The Status of the OECD Transfer Pricing Guidelines in the Post-BEPS Dynamic, May 27, 2020, https://www.ibfd.org/doi/2rpcabz
  11. Knowledge Networking Event, Arm’s Length Principle Analysis on Tax Avoidance through Transfer Pricing Post-Pandemic, July 18, 2023, https://knepublishing.com/index.php/KnE-Social/article/view/13648
  12. WWKN, Cost-Plus Contracts in Multinational Enterprises: A Detailed Overview from a German Perspective, October 11, 2024, https://wwkn.de/en/blog/cost-plus-contracts-in-multinational-enterprises-a-detailed-overview-from-a-german-perspective/
  13. Transfer Pricing in the Digital Age: What GCC Businesses Need to Know, August 1, 2024, https://www.linkedin.com/pulse/transfer-pricing-digital-age-what-gcc-businesses-need-wahaj-siddiqui-etrgf
  14. United Nations Practical Manual on Transfer Pricing, Chapter 6, https://assets.kpmg.com/content/dam/kpmg/ua/pdf/2016/12/UN_Manual_TransferPricing (6).pdf
  15. OECD Transfer Pricing Guidelines, Chapter II Transfer Pricing Methods Part I, http://tayros.bg/wp-content/uploads/2025/02/OECD-Transfer-Pricing-Guidelines-for-Multinational-Enterprises-and-Tax-Administrations-2022-Transfer-pricing-methods.pdf
  16. Transfer Pricing: Purpose of Determination and Factors Affecting Transfer Pricing Determination, December 23, 2020, https://hdpublication.com/index.php/jdmps/article/view/48
  17. RoyaltyRange, Challenges of the Cost Plus Method, April 16, 2025, https://www.royaltyrange.com/news/challenges-of-the-cost-plus-method/
  18. Cost-Plus Method Definition, AccountX, March 22, 2025, https://accountx.co.il/en/cost-plus-pricing-method/
  19. How to Use Cost-Plus Pricing Effectively, Flintfox, August 28, 2024, https://www.flintfox.com/resources/articles/use-cost-plus-pricing-effectively/
  20. IBFD, Case SAC 2021:66 on Group Internal Financing, August 13, 2021, https://www.ibfd.org/doi/12gs0j3
  21. IBFD, Administrative Court of Appeals Case on Netting Subsidies and Costs under Cost-Plus Method, January 25, 2017, https://www.ibfd.org/doi/29myygn
  22. Journal of Tax Studies and Academic Research, Evaluating Transfer Pricing Methodologies for Multinational Enterprises in Zambia, May 1, 2025, https://ijcsacademia.com/index.php/eafj/article/view/259
  23. The Deceptive Cost-plus Method, Exactera, July 6, 2023, https://exactera.com/resources/the-deceptive-cost-plus-method/
  24. BDO Malta, Transfer Pricing: Low Value-Adding Services, January 28, 2025, https://www.bdo.com.mt/en-gb/insights/transfer-pricing-insights/transfer-pricing-low-value-adding-services
  25. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010, https://www.oecd.org/content/dam/oecd/en/publications/reports/2010/08/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-2010_g1g1127e/tpg-2010-en.pdf
  26. Journal of Research in Social Science and Economics, Methodological Tools for Making Management Decisions on Transfer Pricing, November 2, 2023, http://esd-journal.sumy.ua/index.php/journal/article/view/28
  27. OECD Transfer Pricing Guidelines, OECD Malta, May 16, 2025, https://www.bdo.com.mt/en-gb/services/tax/transfer-pricing/oecd-transfer-pricing-guidelines
  28. Cost Plus Pricing as a Sustainable Solution for MSMEs Case Study, International Journal of Economics Finance and Management, May 31, 2024, https://ijefm.co.in/v7i5/Doc/62.pdf
  29. Cost-Plus Pricing Strategy at Motor Workshop, New in Era, July 4, 2024, https://newinera.com/index.php/JournalLaBisecoman/article/view/1323
  30. Transfer pricing rules, OECD guidelines, and market distortions, Journal of Public Economics, November 1, 2009, https://onlinelibrary.wiley.com/doi/10.1111/jpet.12075
  31. Unsuccessful Implementation of the OECD Transfer Pricing Guidelines in Low-Income Countries: The Case of Ethiopia, May 1, 2024, https://opendocs.ids.ac.uk/opendocs/handle/20.500.12413/18383
  32. IBFD, The French Supreme Administrative Court Provides Useful Clarifications on the Deduction of Government Subsidies from the Cost Base, December 6, 2018, https://www.ibfd.org/doi/2y6wm1v
  33. Challenges And Limitations Of Cost Benchmarking, FasterCapital, January 1, 2024, https://fastercapital.com/topics/challenges-and-limitations-of-cost-benchmarking.html
  34. Guidance on Transfer Pricing Documentation and Country-by-Country Reporting, OECD, 2014, https://www.oecd.org/content/dam/oecd/en/publications/reports/2014/09/guidance-on-transfer-pricing-documentation-and-country-by-country-reporting_g1g46cfd/9789264219236-en.pdf
  35. Transfer Pricing documentation, BDO Malta, March 20, 2025, https://www.bdo.com.mt/en-gb/insights/transfer-pricing-insights/transfer-pricing-documentation
  36. Tax Technology in the Field of Financial Transactions Transfer Pricing, IBFD, July 28, 2022, https://www.ibfd.org/doi/3wzpv3v
  37. 2022 Transfer Pricing Decree, Meijburg & Co Tax & Legal, https://www.meijburg.com/news/2022-transfer-pricing-decree
  38. Transfer pricing: un modelo de análisis de comparabilidad de operaciones crediticias, October 7, 2022, https://revistas.cef.udima.es/index.php/RCyT/article/view/7647
  39. Apakah Transfer Pricing Documentation Meningkatkan Kepatuhan Pajak, November 30, 2022, https://jurnal.pknstan.ac.id/index.php/pkn/article/view/1864
  40. IBFD, Guaranteed Unclarity? – A Critical Analysis of Paragraph 10.161 of the OECD Transfer Pricing Guidelines, July 12, 2023, https://www.ibfd.org/doi/3fz5r76
  41. Insights on the Ultimate Guide to Transfer Pricing, Number Analytics, April 18, 2025, https://www.numberanalytics.com/blog/ultimate-transfer-pricing-guide
  42. Transfer Pricing in the Digital Age: What GCC Businesses Need to Know, August 1, 2024, https://www.linkedin.com/pulse/transfer-pricing-digital-age-what-gcc-businesses-need-wahaj-siddiqui-etrgf
  43. Insights on the Ultimate Guide to Transfer Pricing, Number Analytics, April 18, 2025, https://www.numberanalytics.com/blog/ultimate-transfer-pricing-guide
  44. Cost Plus Pricing as a Sustainable Solution for MSMEs Case Study, International Journal of Economics Finance and Management, May 31, 2024, https://ijefm.co.in/v7i5/Doc/62.pdf
  45. WWKN, Cost-Plus Contracts in Multinational Enterprises: A Detailed Overview from a German Perspective, October 11, 2024, https://wwkn.de/en/blog/cost-plus-contracts-in-multinational-enterprises-a-detailed-overview-from-a-german-perspective/
  46. Cost-Plus Pricing Strategy at Motor Workshop, New in Era, July 4, 2024, https://newinera.com/index.php/JournalLaBisecoman/article/view/1323
  47. How to Use Cost-Plus Pricing Effectively, Flintfox, August 28, 2024, https://www.flintfox.com/resources/articles/use-cost-plus-pricing-effectively/
  48. BDO Malta, Transfer Pricing: Low Value-Adding Services, January 28, 2025, https://www.bdo.com.mt/en-gb/insights/transfer-pricing-insights/transfer-pricing-low-value-adding-services
  49. Academy of Tax Law, The Cost Plus Method in Transfer Pricing, July 8, 2024, https://academyoftaxlaw.com/cost-plus-method-transfer-pricing/
  50. Tax Risk Management, The Cost Plus Method in Transfer Pricing, https://www.taxriskmanagement.com/cost-plus-method-transfer-pricing/
  51. Transfer Pricing: Purpose of Determination and Factors Affecting Transfer Pricing Determination, December 23, 2020, https://hdpublication.com/index.php/jdmps/article/view/48
  52. RoyaltyRange, Challenges of the Cost Plus Method, April 16, 2025, https://www.royaltyrange.com/news/challenges-of-the-cost-plus-method/
  53. Challenges And Limitations Of Cost Benchmarking, FasterCapital, January 1, 2024, https://fastercapital.com/topics/challenges-and-limitations-of-cost-benchmarking.html
  54. The Deceptive Cost-plus Method, Exactera, July 6, 2023, https://exactera.com/resources/the-deceptive-cost-plus-method/
  55. Challenges And Limitations Of Cost Benchmarking, FasterCapital, January 1, 2024, https://fastercapital.com/topics/challenges-and-limitations-of-cost-benchmarking.html
  56. Transfer pricing rules, OECD guidelines, and market distortions, Journal of Public Economics, November 1, 2009, https://onlinelibrary.wiley.com/doi/10.1111/jpet.12075
  57. Transfer Pricing in the Digital Age: What GCC Businesses Need to Know, August 1, 2024, https://www.linkedin.com/pulse/transfer-pricing-digital-age-what-gcc-businesses-need-wahaj-siddiqui-etrgf
  58. The Deceptive Cost-plus Method, Exactera, July 6, 2023, https://exactera.com/resources/the-deceptive-cost-plus-method/
  59. Unsuccessful Implementation of the OECD Transfer Pricing Guidelines in Low-Income Countries: The Case of Ethiopia, May 1, 2024, https://opendocs.ids.ac.uk/opendocs/handle/20.500.12413/18383
  60. Journal of Research in Social Science and Economics, Methodological Tools for Making Management Decisions on Transfer Pricing, November 2, 2023, http://esd-journal.sumy.ua/index.php/journal/article/view/28
  61. WWKN, Cost-Plus Contracts in Multinational Enterprises: A Detailed Overview from a German Perspective, October 11, 2024, https://wwkn.de/en/blog/cost-plus-contracts-in-multinational-enterprises-a-detailed-overview-from-a-german-perspective/
  62. Tax Technology in the Field of Financial Transactions Transfer Pricing, IBFD, July 28, 2022, https://www.ibfd.org/doi/3wzpv3v
  63. 2022 Transfer Pricing Decree, Meijburg & Co Tax & Legal, https://www.meijburg.com/news/2022-transfer-pricing-decree
  64. Guidance on Transfer Pricing Documentation and Country-by-Country Reporting, OECD, 2014, https://www.oecd.org/content/dam/oecd/en/publications/reports/2014/09/guidance-on-transfer-pricing-documentation-and-country-by-country-reporting_g1g46cfd/9789264219236-en.pdf
  65. Transfer Pricing documentation, BDO Malta, March 20, 2025, https://www.bdo.com.mt/en-gb/insights/transfer-pricing-insights/transfer-pricing-documentation
  66. Insights on the Ultimate Guide to Transfer Pricing, Number Analytics, April 18, 2025, https://www.numberanalytics.com/blog/ultimate-transfer-pricing-guide
  67. IBFD, Guaranteed Unclarity? – A Critical Analysis of Paragraph 10.161 of the OECD Transfer Pricing Guidelines, July 12, 2023, https://www.ibfd.org/doi/3fz5r76
  68. Tax Technology in the Field of Financial Transactions Transfer Pricing, IBFD, July 28, 2022, https://www.ibfd.org/doi/3wzpv3v
  69. Insights on the Ultimate Guide to Transfer Pricing, Number Analytics, April 18, 2025, https://www.numberanalytics.com/blog/ultimate-transfer-pricing-guide
  70. Transfer Pricing in the Digital Age: What GCC Businesses Need to Know, August 1, 2024, https://www.linkedin.com/pulse/transfer-pricing-digital-age-what-gcc-businesses-need-wahaj-siddiqui-etrgf
  71. OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, https://www.oecd.org/content/dam/oecd/en/publications/reports/2022/01/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-2022_57104b3a/0e655865-en.pdf
Table of Contents