Ministerial Decision No. 55 of 2025 specifies the authorized Transfer Pricing methods for determining Arm's Length Prices. Article 72 lists the standard methods: Comparable Uncontrolled Price (CUP), Resale Price, Cost Plus Margin, Transactional Net Margin (TNMM), and Transactional Profit Split. It permits the use of alternative methods only if standard options are proven inadequate to determine an Arm's Length Price. Taxpayers are strictly required to document the rationale and assumptions justifying their selected pricing methodology.
CHAPTER 10 - TRANSFER PRICING FOR RELATED PERSONS
Article 72 - Transfer Pricing Methods between Related Persons
To apply the Arm’s Length Principle, the Taxpayer must use the most appropriate of the following methods to price transactions with related Persons:
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