The Law (clause 3 of Article 34) prescribes 5 standard transfer pricing methods for determining the market level of transaction prices (it is also permissible to use a combination of these methods):
- The comparable uncontrolled price method
- The resale price method
- The cost-plus method
- The transactional net margin method
- The profit split method
The method or combination of methods to be used is the one that provides the most reliable determination of the market level of prices ("the most reliable transfer pricing method") based on the terms and characteristics of the transaction in question, the economic circumstances in which it takes place, and the functions, risks, assets and business strategies of the parties to the transaction.
At the same time, taxpayers have the option of using a different transfer pricing method if none of those listed above can reasonably be used.