§ 1.482-1(c)(2)(ii)(A) Completeness and accuracy of data.

Category: (c) Best method rule, Transfer Pricing Guidelines, US IRC Section 482 on Transfer Pricing, § 1.482-1 Allocation of income and deductions among taxpayers | Tag: , , , ,
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The completeness and accuracy of the data affects the ability to identify and quantify those factors that would affect the result under any particular method. For example, the completeness and accuracy of data will determine the extent to which it is possible to identify differences between the controlled and uncontrolled transactions, and the reliability of adjustments that are made to account for such differences. An analysis will be relatively more reliable as the completeness and accuracy of the data increases.






Related Guidelines


Related Case Law

  1. South Africa vs ABC (PTY) LTD, January 2021, Tax Court of Johannesburg, Case No IT 14305ABC Ltd is in the business of manufacturing, importing, and selling chemical products. It has a catalyst division that is focused on manufacturing and selling catalytic converters (catalysts). Catalysts are used in the abatement of harmful exhaust emissions from motor vehicles. To produce...
  2. Russia vs PJSC Uralkali, April 2019, Court of Appeal, Case No. А40-29025/2017PJSC Uralkali, produced and sold fertilizers (“potassium chloride”) through a related Swiss trader. Uralkali had informed the authorities about the controlled transaction and submitted the required TP documentation. To substantiate the pricing of the transaction they had applied the transactional net margin method...
  3. Ukrain vs Rivneazot, September 2019, Supreme Administrative Court, Case No 817/1737/17The Ukrainian group Rivneazot imports natural gas from – and exports mineral to – foreign related companies. The tax authority carried out an audit and concluded that the controlled prices of these transactions had not been determined in accordance with the arm’s length...