The review of the controlled transaction(s) under examination aims at identifying the relevant factors that will influence the selection of the tested party (where needed), the selection and application of the most appropriate transfer pricing method to the circumstances of the case, the financial indicator that will be tested (in the case of a transactional profit method), the selection of comparables and where relevant the determination of comparability adjustments.
TPG2017 Chapter III paragraph 3.8
Category: A. Performing a comparability analysis, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter III: Comparability Analysis | Tag: Comparability analysis, Comparability analysis - 9 step process, Most appropriate transfer pricing method, Review of the controlled transaction, Tested party« Prev | Next »
TPG2017 Chapter III paragraph 3.20
In order to select and apply the most appropriate transfer pricing method to the circumstances of the case, information is needed on the comparability factors in...TPG2017 Chapter III paragraph 3.5
In practice, this process is not a linear one. Steps 5 to 7 in particular might need to be carried out repeatedly until a satisfactory conclusion...TPG2017 Chapter III paragraph 3.23
As explained above, transfer pricing analysis necessitates some information to be available about foreign associated enterprises, the nature and extent of which depends especially on the...TPG2017 Chapter III paragraph 3.9
Ideally, in order to arrive at the most precise approximation of arm’s length conditions, the arm’s length principle should be applied on a transaction-by-transaction basis. However,...TPG2017 Chapter III paragraph 3.7
The “broad-based analysis” is an essential step in the comparability analysis. It can be defined as an analysis of the industry, competition, economic and regulatory factors...
TP case laws
Denmark vs. Danish Production A/S, Feb 2018, Tax Tribunal, SKM2018.62.LSR