Transactions & Industries
FAR profiles and benchmarking for distributors, shared services, KPO, manufacturers, R&D, intangibles and intra-group finance.
Limited-Risk Distributor: FAR Profile & Benchmarking Guide
Building a defensible FAR profile and TNMM benchmark for a limited-risk distributor in India — functions, risks, PLI choice and the right comparable pool.
Read docKPO Transfer Pricing in India: A Benchmarking Guide
A practical FAR profile and TNMM benchmarking guide for KPO entities in India — classification, PLI choice and comparability nuances.
Read docShared Services TP: Benefit Test, Cost Pools and Allocation Keys
The transfer pricing of shared service centres: the benefit analysis that determines whether a charge is owed, cost pool design, allocation keys that match the benefit, and LVAS marking-up.
Read docContract Manufacturing TP: Cost Base, Mark-Up and Capacity Issues
Transfer pricing for contract and toll manufacturers: toll versus contract manufacturing, the cost base line by line, capacity utilization, the TNMM fallback and the audit issues.
Read docContract R&D vs Entrepreneurial R&D: DEMPE and Cost-Based Returns
The line between routine contract R&D and entrepreneurial R&D: who performs the DEMPE functions, who controls the risk, who owns the IP, and what each side earns under each characterization.
Read docIntangibles TP: Licensing, Royalties, DEMPE and HTVI
The transfer pricing of intangibles: the royalty benchmark problem, DEMPE allocation, cost sharing, hard-to-value intangibles, and the Indian practice on royalties.
Read docIntercompany Loans, Guarantees & Cash Pooling: TP Documentation
The transfer pricing of intra-group finance: the independent-lender test for loans, the genuine-benefit test for guarantees, cash pooling net positions, and the documentation each requires.
Read docSoftware and SaaS Transfer Pricing: From Licensing to Profit Splits
The transfer pricing of software and SaaS: the different economics of licensing versus subscriptions, the royalty benchmark problem, DEMPE, and when the profit split is the right answer.
Read docGroup Restructuring TP: Exit Charges, Location Savings and ThinCap
The transfer pricing of group restructurings: the business rationale that has to exist first, exit charges, the apportionment of location savings, thin capitalization, and the documentation sequence.
Read docIntercompany Agreements: Legal Form Aligned with Economic Substance
The clauses that carry the transfer pricing file: scope, IP ownership, pricing mechanics, term and termination — and why the agreement must match the actual conduct, not just describe it.
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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.