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April 17, 2025
15 min read

Transfer Pricing Ranges: How Quartile Calculations Vary Worldwide

Borys

Borys

CEO of ArmsLength AI

Transfer Pricing Ranges: How Quartile Calculations Vary Worldwide

TL;DR - Key Takeaways

  • The IQR calculation method varies significantly between the IRS, OECD countries, India, and other jurisdictions, potentially affecting your arm's length range.
  • India uses a narrower 35th-65th percentile range compared to the standard 25th-75th percentile used by most other countries.
  • Small differences in calculation methods can have material impacts on borderline cases, affecting compliance and audit outcomes.
  • Understanding jurisdiction-specific requirements is crucial for accurate documentation and successful audit defense.

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