The best argument for any transfer price is the "arms-length rule". If the company in Country B could buy the same product from an unrelated company for $100.00 that would be an easily established and defendable transfer price. In the absence of such examples, many other factors must be considered such as margins in both countries, administrative costs of selling to a related entity vs an unrelated one, etc. | The best argument for any transfer price is the "arms-length rule". If the company in Country B could buy the same product from an unrelated company for $100.00 that would be an easily established and defendable transfer price. In the absence of such examples, many other factors must be considered such as margins in both countries, administrative costs of selling to a related entity vs an unrelated one, etc. |