I would like to write an email to my Tax Client "Novo Nordisk" that is my Pharmaceutical Client that deals mainly in curing Diabetes patient and insulin pens. I am writing an email to them pertinent to ask them to provide the respective data and material which could be required to perform Benchmarking Study in accordance with OECD pertinent to conduct "Resale Price Method". I have written the following List of Required(LoR) which are as follows : 1. Competitor's data of Identical Products, 2. Retail price of Competitor's, 3. IQVIA Magazine details, 4. Differentiate between Tender Sale & Normal Business to segregate the respective revenue streams. +I would like to request ChatGPT to add more details which would be required to conduct benchmarking study in accordance with OECD Guidelines as per Resale Price Method. + Kindly note my client is the importer of products and then distribute the products locally in the market through sub-distributors. Further to that it is in Business of Pharma Sector that is being regulated by DRAP. I would like to Request ChatGPT add maximum details which is being required to conduct benchmarking as per Resale Price Method. Below I have written about the Resale Method which is being mentioned in OECD Guidelines Summary of the Resale Price Method: • The resale price method is a transfer pricing method used to determine the arm's length price of a product purchased from an associated enterprise and resold to an independent enterprise. • The resale price is reduced by a resale price margin, which represents the amount the reseller needs to cover its selling expenses and make a reasonable profit. • After subtracting the resale price margin and adjusting for other costs associated with the purchase (e.g., customs duties), the remaining amount is considered the arm's length price of the original transfer of property. • The resale price margin can be determined by comparing the margin earned by the reseller in controlled transactions to margins earned in comparable uncontrolled transactions (internal and external comparables). • Comparability is essential in the resale price method, and adjustments may be necessary to account for differences in product characteristics, functions performed, and economic circumstances. • The method is particularly useful in marketing operations but requires careful consideration when valuable or unique intangibles are involved. • Differences in business operations, costs, and functions between associated and independent enterprises should be analyzed to ensure comparability. • The reliability of the method may be affected by time gaps between purchase and resale, changes in the market, costs, and other factors. • The level of activities performed by the reseller and its contribution to the value of the product influence the resale price margin. • The method may be less reliable in cases where goods undergo further processing or lose their identity, or when the reseller contributes significantly to intangible property associated with the product. • In a distribution chain involving intermediate companies, the functions performed and the prices paid by the intermediate company should be considered. • Exclusive rights to resell goods and differences in accounting practices may also impact the resale price margin and require appropriate adjustments. • When using the resale price method, it is important to adjust for differences in the functions performed by the distributors. For example, if one distributor offers a warranty and the other does not, the gross profit margin of the distributor offering the warranty will be higher. This difference must be adjusted for in order to make the margins comparable. • If the warranty function is performed by the supplier, the adjustment for the difference in margins may be automatic if the cost of performing the warranty is accounted for as a cost of goods sold. However, if the warranty expenses are accounted for as operating expenses, there will be a distortion in the margins that must be corrected. • When comparing the margins of a subsidiary to those of independent distributors, it is important to consider whether the subsidiary performs any additional functions that the independent distributors do not. For example, if the subsidiary has an exclusive sales arrangement or performs technical applications for the customers, its margins may be higher than those of the independent distributors. In this case, it may be necessary to adjust the margins of the subsidiary to achieve comparability. The aforesaid content has been provide to ChatGPT to use the same but very smartly and in a Professionalize manner to draft, craft and prepared the best of out of it the knowledge from it and use it very precisely efficiently and effective