In practice, examining multiple year data is often useful in a comparability analysis, but it is not a systematic requirement. Multiple year data should be used where they add value to the transfer pricing analysis. It would not be appropriate to set prescriptive guidance as to the number of years to be covered by multiple year analyses.
TPG2017 Chapter III paragraph 3.75
Category: B. Timing issue in comparability, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter III: Comparability Analysis | Tag: Comparability analysis, Multiple year data« Prev | Next »
TPG2017 Chapter I paragraph 1.111