Transfer Pricing Safe Harbor
Simplified TNMM and Comparable Profits method for related-party transactions. We calculate the arm's length range, documentation threshold, and safe harbor compliance.
Model parent–subsidiary, sister-company, or contract manufacturer/distributor structures.
| Country | Formal safe harbor | Doc threshold | ETR | Penalty |
|---|---|---|---|---|
| 🇮🇪 Ireland | No | €5M (EU Local File) | 12.5% | 20% |
| 🇺🇸 USA | No | $10M (Section 6662(e)) | 25.0% | 20% |
| 🇮🇳 India | Yes | ₹20cr (Form 3CEB) | 25.0% | 100% |
| 🇸🇬 Singapore | Yes | S$15M | 17.0% | 0% |
| 🇧🇷 Brazil | Yes | R$50M | 34.0% | 75% |
| 🇩🇪 Germany | No | €5M (Local File) | 30.0% | 10% |
| 🇳🇱 Netherlands | No | €5M (Local File) | 25.5% | 10% |
Guide to transfer pricing safe harbor
Simplified TNMM under OECD Guidelines paragraph 3.82 uses pre-built industry benchmarks and a fixed interquartile range instead of a multi-month comparable search. It is valid for SMEs, low-value-adding services, and routine distribution/manufacturing under €50M. Pair it with the country safe harbor (India IT/ITES 17–23%, Singapore 5% CP, Brazil fixed margins) and apply Pillar Two if your group exceeds €750M consolidated revenue.
FAQ
How does the transfer pricing safe harbor calculator work?
Enter your industry, business model, margin and countries. We apply OECD simplified TNMM with pre-built benchmarks, check country safe harbor rules, documentation thresholds, and Pillar Two impact.
Transfer pricing for my two-company structure
Select tested party (the simpler entity — usually distributor or service provider) and counterparty. We calculate arm's length range, the dollar adjustment to median, and the profit allocation between both entities.
What is TNMM simplified?
Pre-built industry benchmarks with a fixed interquartile range, no working capital adjustments. Valid for SMEs and low-value services under OECD Guidelines paragraph 3.82.
Which countries have formal safe harbors?
India (IT/ITES 17–23%), Singapore (5% cost-plus services), Brazil (fixed margins by sector). USA, Ireland, Germany, Netherlands have no formal safe harbor but accept OECD methodology.
What are the documentation thresholds?
USA $10M (Section 6662(e)), EU €5M (Local File), India ₹20cr (Form 3CEB), Singapore S$15M, Brazil R$50M.
How does BEPS 2.0 Pillar Two interact with safe harbor?
If consolidated revenue ≥ €750M and effective rate < 15%, a top-up tax applies. The 12.5% Ireland rate becomes effectively 15% via QDMTT or US IIR.
How accurate are the benchmarks?
Medians come from BvD Orbis and Compustat, filtered by SIC/NAICS. Country rules are updated from CBDT, IRAS, IRS, OECD.
Is there an API?
Yes. REST API returns arm's length range, safe harbor status, documentation check, Pillar Two impact. Free 200 req/day; Pro $5/mo.