Transfer Pricing: Transactional Profit Methods – Now more acceptable?

Tax administrators world over, as also OECD, have come to realise the inherent limitations of traditional transaction methods and in the process Transactional Profit Methods have gained greater acceptance than before. This is evident from the suggested amendments in ‘Transfer Pricing Guidelines for Multinational Enterprises and tax Administrators’ issued by OECD in 1995. They are no longer transfer pricing methods of last resort.