Transfer Pricing Basics
The arm’s length principle, related parties, functional analysis, OECD and BEPS — the concepts every TP professional works from.
What is Transfer Pricing? A Complete Beginner's Guide (2026)
Transfer pricing explained from first principles — what it is, why tax authorities care, who must comply, and how a TP study and TP documentation fit together.
Read docThe Arm's Length Principle Explained (OECD and India)
The arm's length principle in full: the OECD Article 9 standard, India's section 92, how a price gets tested against independent evidence, and how the principle shows up in an audit.
Read docRelated Parties & Controlled Transactions: Who and What Counts
The Indian associated-enterprise tests under s.92(2), ownership and control thresholds, the transaction types that trigger transfer pricing, and how OECD definitions compare.
Read docFunctional Analysis (FAR): Functions, Assets and Risks
The functional analysis in working depth: the F/A/R framework, how to draw a profile from the contracts and the organisation, and how the FAR drives the tested party, the method and the PLI.
Read docComparability Analysis: 5 Factors, 2 Screens, the Adjustments Rule
How comparability works in transfer pricing — the five comparability factors, quantitative vs qualitative screening, when to adjust versus exclude, and what survives TPO review.
Read docOECD Transfer Pricing Guidelines: A Reader’s Map (2026)
A chapter-by-chapter map of the OECD Transfer Pricing Guidelines — what each chapter governs, the provisions practitioners cite most, and how Indian rules mirror or deviate.
Read docThe BEPS Initiative: What TP Teams Must Know (2026)
OECD/G20 BEPS in plain terms — the 15 actions, the ones that matter for day-to-day transfer pricing (7, 8-10, 13), and India’s implementation status.
Read docRoutine vs Entrepreneurial: DEMPE and Who Captures the Profit
The routine/entrepreneurial divide in transfer pricing — DEMPE functions, control of risk, intangible ownership, and how the divide decides method and profit pool.
Read docTransfer Pricing Risk: What Happens When Prices Are Challenged
The anatomy of a transfer pricing challenge — TPO adjustments, interest and penalty exposure in India, common audit triggers, and the de-risking checklist that prevents most of them.
Read docTransfer Pricing vs Customs Valuation vs Management Pricing
Three different "transfer prices" that teams confuse — the tax transfer price, the customs dutiable value, and the internal management price — and which one your TP file must support.
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Go from guide to finished study
Quartyl applies the method, PLI and screening steps above automatically — with documented reasons for every exclusion.