TPG2017 Chapter III paragraph 3.77

Category: B. Timing issue in comparability, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter III: Comparability Analysis | Tag: , ,
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Multiple year data will also be useful in providing information about the relevant business and product life cycles of the comparables. Differences in business or product life cycles may have a material effect on transfer pricing conditions that needs to be assessed in determining comparability. The data from earlier years may show whether the independent enterprise engaged in a comparable transaction was affected by comparable economic conditions in a comparable manner, or whether different conditions in an earlier year materially affected its price or profit so that it should not be used as a comparable.

TP guidelines

TPG2017 Chapter III paragraph 3.76
In order to obtain a complete understanding of the facts and circumstances surrounding the controlled transaction, it generally might be useful to examine data from both...
TPG2017 Chapter I paragraph 1.111
The existence of a cycle (e.g. economic, business, or product cycle) is one of the economic circumstances that should be identified. See paragraph 3.77 in relation...
TPG2017 Chapter III paragraph 3.79
The use of multiple year data does not necessarily imply the use of multiple year averages. Multiple year data and averages can however be used in...
TPG2017 Chapter III paragraph 3.75
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...
TPG2017 Chapter III paragraph 3.74
Data from years following the year of the transaction may also be relevant to the analysis of transfer prices, but care must be taken to avoid...

TP case laws