Profit split method
The profit split method divides the combined profit from a related-party transaction between the entities involved in proportion to each one's relative economic contribution, typically used when both hold valuable intangibles.
FrameworkOECD Transfer Pricing Guidelines
See it move
A manufacturer and a distributor jointly generate a combined operating profit of €500,000. The group allocates it using relative development spend: the manufacturer spent €240,000 and the distributor €160,000, a total of €400,000. The manufacturer's 60% share gives it €300,000; the distributor's 40% share gives it €200,000, and the two shares add back to the full €500,000.
The formula
Variables
- Entity i's allocated profit (€)
- Combined profit (€)
- Entity i's contribution key (€ (or other allocation base))
- Total of all entities' contribution keys (same unit as kᵢ)
Allocates the combined profit of a related-party transaction between the entities in proportion to their relative contribution.