TPG2017 Chapter III paragraph 3.59

Category: A. Performing a comparability analysis, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter III: Comparability Analysis | Tag: , , ,
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Where the application of the most appropriate method (or, in relevant circumstances, of more than one method, see paragraph 2.12), produces a range of figures, a substantial deviation among points in that range may indicate that the data used in establishing some of the points may not be as reliable as the data used to establish the other points in the range or that the deviation may result from features of the comparable data that require adjustments. In such cases, further analysis of those points may be necessary to evaluate their suitability for inclusion in any arm’s length range.

TP guidelines

TPG2017 Chapter III paragraph 3.63
Extreme results might consist of losses or unusually high profits. Extreme results can affect the financial indicators that are looked at in the chosen method (e.g....
TPG2017 Chapter III paragraph 3.62
In determining this point, where the range comprises results of relatively equal and high reliability, it could be argued that any point in the range satisfies...
TPG2017 Chapter III paragraph 3.60
If the relevant condition of the controlled transaction (e.g. price or margin) is within the arm’s length range, no adjustment should be made....
TPG2017 Chapter III paragraph 3.58
A range of figures may also result when more than one method is applied to evaluate a controlled transaction. For example, two methods that attain similar...
TPG2017 Chapter III paragraph 3.2
As part of the process of selecting the most appropriate transfer pricing method (see paragraph 2.2) and applying it, the comparability analysis always aims at finding...

TP case laws