OECD COVID-19 TPG paragraph 52

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First, exceptional costs should generally be excluded from the net profit indicator except when those costs relate to the controlled transaction as accurately delineated.29 The exclusion of exceptional costs must be done consistently at the level of the tested party and the comparables to ensure a reliable outcome, noting that the availability of this information may be limited.30 Care should be taken in order to ensure that such costs are appropriately measured and are consistently accounted for to the extent possible.

29 Paragraph 2.86 of Chapter II of the OECD TPG.
30 Paragraph 2.74 of Chapter II of the OECD TPG.






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