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Strategic Flexibility: TNMM in Transfer Pricing Analysis

In the intricate landscape of transfer pricing, the Transactional Net Margin Method (TNMM) stands out as the “joker,” renowned for its exceptional flexibility and adaptability across diverse business models. Let’s explore why TNMM is rightfully regarded as the adaptive foundation of transfer pricing methodologies, especially in collaboration with Andersen Egypt:

Flexibility in Profit Level Indicator (PLI)

TNMM sets itself apart by offering unparalleled flexibility in selecting Profit Level Indicators (PLIs). Whether it’s operating profit margin, net profit margin, or return on assets, TNMM accommodates various indicators, making it suitable for a wide spectrum of industries and business structures. Andersen’s expertise further refines this flexibility, tailoring TNMM to meet the unique needs of businesses.

Broad Applicability

TNMM’s allure lies in its extensive applicability. Whether applied to tangible goods or services, TNMM emerges as a versatile method suitable for a diverse array of transactions and business models.

Focus on Net Profit Margin

TNMM’s emphasis on net profit margin provides a comprehensive view of overall profitability. This proves invaluable in situations where a simple price markup might overlook the intricate economic dynamics of a transaction. Andersen’s insight augments this focus, ensuring a nuanced understanding of the financial landscape.

Comparability Adjustments

Recognizing the intricacies of the business environment, TNMM offers flexibility in making comparability adjustments to financial data. This capability enhances the comparability between the tested party and comparable uncontrolled transactions or companies.


TNMM earns its reputation for practicality, particularly in scenarios where detailed transactional data is readily available. Its relative ease of application sets it apart from methods requiring a detailed analysis of specific internal or external comparable.

Global Acceptance

Endorsed by the Organization for Economic Co-operation and Development (OECD) guidelines, TNMM enjoys widespread global acceptance. Its recognized status contributes to its “joker” characterization, signifying its applicability across various jurisdictions.


Despite TNMM’s inherent flexibility, a note of caution is crucial. Successful application, with Andersen’s collaborative approach, requires a meticulous analysis of comparability factors, accurate financial data, and strict adherence to local regulations. The selection of the most fitting transfer pricing method remains contingent on the unique facts and circumstances of each case.

While the term “joker” highlights TNMM’s adaptability, approaching transfer pricing with a comprehensive understanding of the specific business context and relevant regulations is essential. In collaboration with Andersen, TNMM emerges not merely as a joker but as a strategic player, seamlessly adapting to the ever-evolving dynamics of global business with precision and expertise.

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Written By

Sohila Mahmoud - Transfer Pricing Lead

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