“Berry ratios” are defined as ratios of gross profit to operating expenses. Interest and extraneous income are generally excluded from the gross profit determination; depreciation and amortisation may or may not be included in the operating expenses, depending in particular on the possible uncertainties they can create in relation to valuation and comparability.
TPG2022 Chapter II paragraph 2.106
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Category: OECD Transfer Pricing Guidelines (2022), TPG 2022 Chapter II: Transfer Pricing Methods | Tag: Adjustment for depreciation/amortisation, Berry Ratio, Cost base, Denominator - operating expenses, Net Profit Indicator/Profit Level Indicator (PLI), TNMM, Transfer pricing methods
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