It starts at the price the reseller charges its own customers and works back. From that resale price you deduct a gross margin that a comparable independent reseller earns, and the result is the price the related supplier should have charged. The margin has to cover the reseller's selling costs and leave it a return appropriate to what it does and the risks it takes. So the method tests the reseller rather than the supplier or the product, and it suits a distributor that buys goods and sells them on without transforming them.
Resale price method — meaning in cross-border tax
The meaning of Resale price method in cross-border tax, and what turns on it.
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A method testing the gross margin earned by a reseller, sensitive to consistent classification between cost of sales and operating expense.
Why the term matters
Transfer pricing is the area where the same profit is most easily taxed twice, because one country can adjust and the other need not follow. That is what the terms in this group exist to manage.

The same word, two meanings
A term that carries a bright-line test in one country often carries a facts-and-circumstances test in the other. That difference decides how a file is built long before it decides the tax, because one of them can be answered from a document and the other has to be evidenced.
Where it appears in a filing
Resale price method matters in the contexts below. Each of those pages says what it does there, and what it costs to handle.
What it means for your own file
If Resale price method is in a notice you have received, bring the notice. The definition matters far less than what the sender is actually asking for. Send us the facts and we will tell you what has to be filed and what it costs.
If the term has come up because something has already been filed, the useful question is which years are still open. That answer changes what can be corrected and what can only be explained.
Reviewed for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.
Where international tax accountant comes into this file
Most readers of this page are looking for international tax accountant. What follows sets out how it works for resale price method: who is caught by it, what has to be filed, and what the work costs, agreed before it begins.
What these engagements turn on
Warehousing costs sitting above the gross margin line
A distributor's gross margin looked thin against its comparable set, and the group had been considering a price reduction from the supplier. Reading the comparables' accounting policies showed the difference was classification: the distributor charged warehousing and inbound handling to cost of sales, while most comparables reported them as operating costs. Restating to a common basis moved the margin materially. The engagement produced a restated comparison, a note of each reclassification made, and a conclusion that the original pricing had been within range all along.
A reseller that had quietly become a full-risk distributor
The intercompany arrangement described a limited-risk reseller and the pricing had not changed in six years. In that period the company had taken over inventory planning, begun holding buffer stock, and started funding local advertising. The order of work was functional analysis first, method second. The engagement produced a description of what the company had become, a conclusion that a gross-margin comparison no longer fitted its profile, and an operating-margin analysis with pricing set on that basis from the current year.
Comparable accounts that could not be restated
A benchmarking set assembled for a distribution company drew on accounts prepared under several national frameworks. Some disclosed enough to identify where handling and freight were reported; most did not. Rather than assume, we tested how much of the set could be restated and found too little to support a gross-margin conclusion. The engagement produced a documented reason for setting the method aside, and a replacement analysis on operating margin using the same companies, where the classification differences largely wash out.
One resale margin applied across very different product lines
A group used a single gross margin for everything its distributor sold, from bulk items shipped on pallets to small high-value units requiring cold storage and technical handling. The handling cost per unit of revenue differed by an order of magnitude. The work segmented the distributor's accounts by product line, using its own warehouse and logistics records. The engagement produced separate margins for each line, supported by segmented figures, and an allocation rule the company can maintain from its existing systems.
Explaining a thin resale margin the company did not set
An examination focused on why a distributor earned less than the comparables suggested. The answer was that its resale prices were fixed by a regulated national tariff, so the only variable left was the purchase price. The work evidenced the tariff, showed what it left available as a margin, and analysed whether an independent distributor would have accepted the arrangement at all. The engagement produced a documented explanation of the constraint and a revised supply price that left the distributor a return consistent with its functions.
An agency arrangement described as a distributorship
Contracts called the local company a distributor and the group tested it on a resale margin. In practice the goods were shipped directly to customers, the local company never held title, and the group carried credit risk. There was no resale to price. The work identified what the company actually did, which was customer contact and order administration. The engagement produced a services-based charge matching the activity, corrected contracts, and an assessment of which earlier years needed revisiting.
A Pricing Study That Started With Who Does What
Functions, assets and risks decide which entity should earn the return, and the method follows from that rather than the other way round. Getting the sequence backwards is how a study fails on its first question.
Read how this one runsAn Assignment Priced Without Counting the Days
Nearly every relief in a mobility file — treaty exemption, residence, social security — is decided by a day count that has to be evidenced. The engagement puts the tracking in place at the start, because it cannot be reconstructed at the end.
Read how this one runsAll case studies — every published engagement in one place.
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More on Resale price method
Because the method tests a gross margin, and a gross margin is the figure above operating costs. If your company treats inbound freight, warehousing or warranty provisions as cost of sales while the comparable companies report them below the gross line, the two margins are not measuring the same thing and the comparison is wrong before any analysis begins. This is a common failure in practice, and it is invisible unless someone reads the accounting policies of the comparables rather than just their ratios. Either restate to a common basis or use a method that tests operating profit instead.
It becomes harder as the reseller does more. The method assumes the gross margin rewards a fairly contained set of distribution functions. A reseller that builds the local brand, invests in customer acquisition and bears the risk of that spending is earning a return on something more than resale, and comparable independent resellers with the same profile are difficult to find. Where the additional activity is substantial, the usual course is to test operating profit instead, so that the marketing spend sits inside the tested result rather than distorting the margin above it.
If goods never come into the company's hands and it takes no inventory or credit risk, it is closer to an agent than a reseller, and there may be no resale margin to test at all. The right analysis then looks at the service performed — finding customers, handling paperwork — and prices that, rather than deducting a distribution margin from a resale price. Getting this wrong in either direction is expensive: an agent tested as a distributor is usually over-rewarded, and a full-risk distributor tested as an agent is under-rewarded and will show unexplained profit somewhere.
Then the gross margins may not be comparable, and often cannot be made so from published information. Different frameworks and different national practices put costs in different places, and the disclosure in a set of accounts is rarely detailed enough to restate them reliably. Where restatement is possible you do it and record it. Where it is not, the honest conclusion is that a gross-margin comparison is not available on this evidence, and an operating-margin method carries the position instead. Operating margin is less sensitive to classification, which is precisely why it is used when this problem appears.
It is designed for the resale of goods and it fits awkwardly elsewhere. The logic depends on there being a purchase price, a resale price and a margin between them that pays for the distribution function. A service provider generally has no purchased good to resell, so there is no gross margin of that kind to test, and a cost-based or operating-margin approach describes the economics better. The exception worth noting is the onward supply of a bought-in service with little added to it, where the same reasoning can apply.
Yes, where they are authorised to represent you with that tax authority and the filing is done electronically. What matters is not where the adviser sits but whether they can lawfully act for you and are competent in both systems — a return prepared with no knowledge of the other country is where the relief gets missed. We file on both sides, from offices in India, the USA, Canada and the UAE. See how we work.
You claim relief once, in the right country, in the right order. Usually the source country taxes first, the residence country then gives a credit for that tax against its own charge on the same income, and a treaty caps the source-country rate. Getting the order wrong is what produces a double charge you then have to unwind. The mechanism differs by income type, which is why we map the whole position before filing either return. See how to avoid double taxation.



