A situation where the Berry ratio can prove useful, according to the OECD, is for intermediary activities where a taxpayer purchases goods from a related party and on-sells them to other related parties. In such cases, the resale price method may not be applicable, given the absence of uncontrolled sales, and a cost-plus method that would provide for a markup on the cost of goods sold might not be applicable either where the cost of goods sold consists of controlled purchases. By contrast, operating expenses in the case of an intermediary may be reasonably independent from transfer pricing considerations, unless they are materially affected by related-party costs such as head office charges, rental fees or royalties paid to a related party, so that a Berry ratio may be an appropriate indicator, subject to the comments above.