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.