Choosing the profit level indicator in transfer pricing
November 23, 2011
In transfer pricing, the main problem for practitioners is to choose which method they will use to calculate an arm’s-length price. They must also decide which profit level indicator (PLI) they will select to support their argument.
In the OECD transfer pricing guidelines, several PLI are mentioned. One of them: the Berry ratio (Berry ratio = gross profit / operating expenses) is presented on pages 98 to 100, in the section on transactional net margin.
Sorry. You must be a subscriber to view this article. Alternatively, why not take a free trial? To subscribe and access this article immediately simply click here or call +44(0)207 779 8380.