• Appendix 6: Arm's length methodologies

    Attention

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    This information may not apply to the current year. Check the content carefully to ensure it is applicable to your circumstances.

    End of attention

    The arm's length pricing methodologies should be identified using the codes listed below.

    Arm's length pricing method

    Code

    Comparable uncontrolled price method

    1

    Resale price method

    2

    Cost-plus method

    3

    Profit split method

    4

    Transactional net margin method

    5

    Marginal costing

    6

    Cost-contribution arrangement

    7

    Apportionment of costs

    8

    Apportionment of income

    9

    Fixed mark-up applied to cost

    10

    Fixed percentage of resale price

    11

    Other arm's length methods

    12

    No transfer pricing method used

    13

    Note: The 'fixed mark-up applied to cost' and 'fixed percentage of resale price' methodology codes should be used when 'administrative practice' as described by Taxation Ruling TR 99/1 Income tax: international transfer pricing for intra-group services has been utilised to set the pricing of intra group services.

    Last modified: 09 Nov 2011QC 24292