https://blog.comp-press.com/tags/oecd/ Recent content in OECD on CompPress Blog — Transfer Pricing Insights Hugo en-us Fri, 10 Apr 2026 00:00:00 +0000 https://blog.comp-press.com/blog/what-is-transfer-pricing/ Fri, 10 Apr 2026 00:00:00 +0000 https://blog.comp-press.com/blog/what-is-transfer-pricing/ <h2 id="what-is-transfer-pricing">What Is Transfer Pricing?</h2> <p>Transfer pricing refers to the pricing of transactions between <strong>related entities</strong> within a multinational enterprise (MNE) group. When a US subsidiary buys goods from its German parent, licenses technology from a Japanese affiliate, or receives management services from a UK holding company, the prices for these intercompany transactions are governed by transfer pricing rules.</p> <p>The core principle is straightforward: intercompany prices must reflect what <strong>independent, unrelated parties</strong> would agree to under comparable circumstances. This is called the <strong>arm&rsquo;s length principle</strong>, and it forms the foundation of transfer pricing regulations worldwide.</p> https://blog.comp-press.com/blog/tnmm-vs-cpm/ Tue, 07 Apr 2026 00:00:00 +0000 https://blog.comp-press.com/blog/tnmm-vs-cpm/ <h2 id="understanding-tnmm-and-cpm">Understanding TNMM and CPM</h2> <p>When performing a transfer pricing analysis, the <strong>Transactional Net Margin Method (TNMM)</strong> and the <strong>Comparable Profits Method (CPM)</strong> are by far the most frequently applied methods worldwide. If you work with transfer pricing across multiple jurisdictions, you&rsquo;ll encounter both — and understanding their similarities and differences is essential.</p> <p>At their core, both methods do the same thing: they compare the <strong>net profitability</strong> of the tested party in a controlled transaction against the net profitability of comparable independent companies. The difference lies in the regulatory framework, terminology, and certain application nuances.</p>