tp.alptransfer pricing at arm's lengthDoe & Roe LLC

Engagements › Helios Lane Software › Benchmarking: Contract software development

Benchmarking: Contract software development

Tested party: Helios Lane Development Ltd. Method: TNMM, net cost plus (what is TNMM?). Profit level indicator: Net cost plus (operating profit over total costs), weighted over 2023–2025. Policy target 10.00%.

Comparables accepted or rejected, the range, the tested party against it.

Suggestion, not decision. The screening column is a rules-based first pass over the search strategy. It counts for nothing until a person accepts or rejects the company. The range below uses only companies a person accepted. The comparables are invented; the real ones would come from a licensed database. Process: OECD 3.4, OECD 3.38–3.46.

The policy's 10.00% is above the upper quartile (9.18%): the recipient's tax authority may challenge the excess; the policy is to review — suggestion.

The range is the inclusive (linear, n−1) interquartile range on 8 accepted comparables (OECD 3.57, 3.60).

The Search

Database and search date: to be recorded. The steps the search took are not on file; what the comparables set shows:

Companies in the set12
Flagged for rejection by the screening3
Accepted by a person8
Rejected by a person3
Undecided1

The tested party against the range

7.30%median 8.20%9.18%
tested party 8.70% · interquartile range · ticks: accepted comparables

Helios Lane Development Ltd earned 8.70% in 2025. The range is 7.30% to 9.18%. The result is within the range.

One year's result is set against a multi-year range. Base for any adjustment: €9,751,000 — Trial balance: costs of Development Ltd (Trial balance, Development Ltd).

The Range, by Each Quartile Definition

DefinitionCompaniesLower quartileMedianUpper quartileTested Party
Inclusive (linear, n−1)
Position p·(n−1) counted from zero, interpolated between neighbours. The spreadsheet function QUARTILE.INC.
87.30%8.20%9.18%WithinUsed by this study
Exclusive (linear, n+1)
Position p·(n+1) counted from one, interpolated; the quartiles fall outside the extremes for a small set. The spreadsheet function QUARTILE.EXC.
87.05%8.20%9.84%Within
Nearest rank (for an even count, the median is the lower middle value)
The value at rank ⌈p·n⌉; no interpolation, so every quartile is one of the observations. For an even count the median is the lower of the two middle values.
86.92%7.60%8.86%Within

The interquartile range: OECD 3.57, 3.60. Which definition the practice uses, and the Tax Department's view: Practice policy · to be confirmed by the practice.

The Comparables

8 accepted, 3 rejected, 1 undecided.

CompanyActivity202320242025WeightedScreening SuggestionDecision
Arcwright Engineering Services Ltd
GB
Contract software development for third-party clients5.35%10.53%8.29%7.43%Suggestion Accept
Meets the search strategy: Business description: "Contract software development for third-party clients"; independent; profitable in at least 2 of 3 years.
Accepted
As suggested · Dimitri Wells
Bellhaven Code Labs Sp. z o.o.
PL
Software development services on a time-and-materials basis8.82%9.01%8.67%8.80%Suggestion Accept
Meets the search strategy: Business description: "Software development services on a time-and-materials basis"; independent; profitable in at least 2 of 3 years.
Accepted
As suggested · Dimitri Wells
Corran Systems Development S.R.L.
RO
Outsourced software engineering for product companies10.53%11.33%7.95%9.48%Suggestion Accept
Meets the search strategy: Business description: "Outsourced software engineering for product companies"; independent; profitable in at least 2 of 3 years.
Undecided
Delmont Digital Engineering S.A.
PT
Contract development of web and mobile applications9.22%5.11%7.63%6.79%Suggestion Accept
Meets the search strategy: Business description: "Contract development of web and mobile applications"; independent; profitable in at least 2 of 3 years.
Accepted
As suggested · Dimitri Wells
Ebbsfleet Software Services Ltd
IE
Bespoke software development and testing services11.18%5.41%10.55%8.86%Suggestion Accept
Meets the search strategy: Business description: "Bespoke software development and testing services"; independent; profitable in at least 2 of 3 years.
Accepted
As suggested · Dimitri Wells
Farrowdale Tech Services s.r.o.
CZ
Software development and quality assurance for clients6.57%6.50%8.97%6.92%Suggestion Accept
Meets the search strategy: Business description: "Software development and quality assurance for clients"; independent; profitable in at least 2 of 3 years.
Accepted
As suggested · Dimitri Wells
Glenmorrow Development Centre EOOD
BG
Nearshore software development services11.24%-4.53%-6.08%-0.57%Suggestion Reject
Persistent losses: Operating loss in 2 of the 3 years studied.
Rejected
As suggested · Dimitri Wells
Halberd Code Works Kft.
HU
Contract software engineering and maintenance12.69%11.92%11.81%12.22%Suggestion Accept
Meets the search strategy: Business description: "Contract software engineering and maintenance"; independent; profitable in at least 2 of 3 years.
Accepted
As suggested · Dimitri Wells
Inchcape Lane Engineering Ltd
MT
Develops and sells its own software product6.93%6.73%11.63%8.31%Suggestion Reject
Functionally not comparable: Business description: "Develops and sells its own software product" — contains "software product", which the search strategy excludes.
Rejected
As suggested · Dimitri Wells
Juniperfield Systems d.o.o.
HR
Software development services for related companies8.46%12.46%7.51%9.53%Suggestion Reject
Functionally not comparable: Business description: "Software development services for related companies" — contains "related companies", which the search strategy excludes.
Rejected
As suggested · Dimitri Wells
Kilbride Software Partners S.L.
ES
Custom software development for enterprises11.39%9.83%7.06%10.16%Suggestion Accept
Meets the search strategy: Business description: "Custom software development for enterprises"; independent; profitable in at least 2 of 3 years.
Accepted
As suggested · Dimitri Wells
Larchmont Engineering Services GmbH
AT
Engineering and software development on contract9.33%10.16%5.77%7.60%Suggestion Accept
Meets the search strategy: Business description: "Engineering and software development on contract"; independent; profitable in at least 2 of 3 years.
Accepted
As suggested · Dimitri Wells

Team members on the engagement record the accept and reject decisions. Choose a team member under View As to try it.

Refresh From The Database

Upload this year's export: companies already in the study get their new figures and keep last year's decision; new companies arrive with a screening suggestion for a person to decide. The study's sign-offs reopen. The column layout, with this study's companies.

Team members on the engagement import.

Download The Appendix (CSV)

Sign-Off

ReviewedVerifiedConfirmed

Next: Reviewed, by a team member. Choose a person under View As to sign.

Evidence still outstanding: Board minutes approving the development budget, due 11 Nov 2026 — in 4 days.

Signing is still open: say in what you looked at how the conclusion stands without it.

HashContent hash 24b817ea307a · a change to it reopens every sign-off