[Verse 1] When the subsidiaries trade across the border lines Parent company sets the price, but regulators scrutinize Like strangers in the marketplace, that's how we calculate Arm's length principle governs what related parties negotiate [Chorus] Document, demonstrate, defend your rate CUP, RPM, TNMM - methods we correlate Profit split when functions intertwine Keep your benchmarks sharp, your margins in line Transfer pricing truth - unrelated proof [Verse 2] Comparable uncontrolled price searches databases wide Find transactions in the open where third parties collide Resale price method strips the markup from retail Cost plus adds a margin when the manufacturer sets sail [Chorus] Document, demonstrate, defend your rate CUP, RPM, TNMM - methods we correlate Profit split when functions intertwine Keep your benchmarks sharp, your margins in line Transfer pricing truth - unrelated proof [Bridge] Economic substance over legal form Master file, local file, country reports warm OECD guidelines crystallize the norm Transactional net margin method rides the storm [Verse 3] Functions, assets, risks - analyze the three Who controls decisions, bears uncertainty Profit split apportions when unique value flows Residual method captures what nobody else knows [Chorus] Document, demonstrate, defend your rate CUP, RPM, TNMM - methods we correlate Profit split when functions intertwine Keep your benchmarks sharp, your margins in line Transfer pricing truth - unrelated proof [Outro] Primary adjustment, secondary too Correlative relief when double tax breaks through Contemporaneous records seal your case Arm's length principle - keep that steady pace
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