Transfer Pricing Profit Level Indicators (PLI)

Please Note

The Internal Revenue Service’s Advance Pricing and Mutual Agreement (“APMA”) program develops APMA reference sets for certain industries, including U.S. wholesale distribution and automotive parts manufacturing, in connection with the application of the comparable profits method (“CPM”). These APMA sets are intended to provide analytical consistency and to serve as baseline datasets, which APMA staff may subsequently refine to reflect the facts and circumstances of individual taxpayers. APMA distribution sets are broad in nature and are updated periodically.

Further, it should be noted that APMA generally places less emphasis on Berry ratio results and more frequently reviews return on assets (ROA) results to test the consistency of operating margin outcomes.

Disclaimer

In light of APMA approach, RevUP Advisors has independently developed a broad U.S. distribution set of 39 companies utilizing S&P Global Compustat data as of August 2025. This dataset has been prepared for informational purposes only and may differ in material respects from the most current APMA set. No working capital and other taxpayer-specific adjustments have been applied to the results of this dataset. Some adjustments are mandatory when a taxpayer’s financials and facts are available and may significantly affect the resulting arm’s-length range.

Accordingly, any profit level indicators (PLIs) derived from this dataset are illustrative in nature and should not be construed as definitive benchmarks for any particular taxpayer. The use of this dataset without appropriate taxpayer-specific adjustments and analyses may lead to materially different outcomes. RevUP Advisors, in the context of formal transfer pricing analyses, applies such adjustments and other refinements to support the most defensible and reliable results for its clients.

Any reproduction and uses of the results are prohibited without prior approval of RevUp-Advisors.