Examples of comparability adjustments include adjustments for accounting consistency designed to eliminate differences that may arise from differing accounting practices between the controlled and uncontrolled transactions; segmentation of financial data to eliminate significant non- comparable transactions; adjustments for differences in capital, functions, assets, risks.
TPG2017 Chapter III paragraph 3.48
Category: A. Performing a comparability analysis, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter III: Comparability Analysis | Tag: Adjustments for accounting consistency, Adjustments for differences in capital functions assets risks, Comparability adjustments, Comparability analysis, Segmentation of financial data« Prev | Next »
TPG2017 Chapter III paragraph 3.51