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April 17, 2025
15 min read
Transfer Pricing Ranges: How Quartile Calculations Vary Worldwide
Borys
CEO of ArmsLength AI
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.
- Canada takes a fundamentally different approach, considering the full range rather than statistical trimming.
- 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.
Sources
- U.S. Treasury Regulations §1.482-1(e)(2)(iii)
- OECD Transfer Pricing Guidelines (2022)
- India Income-tax Rules, Rule 10CA
- Canada - Global Transfer Pricing Review - KPMG International
- TPM-16 - Transfer pricing (CRA)
- Transfer pricing (CRA overview)
- Ukraine Cabinet Resolution No. 381 (2015)
- Transfer pricing in Ukraine (Grant Thornton)
- Increase in financial result of certain operations with non- ... (State Tax Service of Ukraine)
- Transfer Pricing Country Profile - Ukraine (OECD)
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