December 2016: EU Study on Comparable Data used for transfer pricing

Posted on | By European Commission
EU-Study-on-Comparables
Related content:
  1. EU Study on the Application of Economic Valuation Techniques (2016)
    The Study on the Application of Economic Valuation Techniques for Determining Transfer Prices of Cross Border Transactions between Members of Multinational Enterprise Groups in the EU provides an overview on...
  2. Chapter V paragraph 5.46
    The requirement to use the most reliable information will usually, but not always, require the use of local comparables over the use of regional comparables where such local comparables are...
  3. Chapter III paragraph 3.27
    Step 4 of the typical process described at paragraph 3.4 is a review of existing internal comparables, if any. Internal comparables may have a more direct and closer relationship to...
  4. Chapter III paragraph 3.29
    There are various sources of information that can be used to identify potential external comparables. This sub-section discusses particular issues that arise with respect to commercial databases, foreign comparables and...
  5. Chapter III paragraph 3.3
    In order for the process to be transparent, it is considered a good practice for a taxpayer that uses comparables to support its transfer pricing, or a tax administration that...
  6. Chapter III paragraph 3.66
    A similar investigation should be undertaken for potential comparables returning abnormally large profits relative to other potential comparables....
  7. Report on the Use of Comparables in the EU (2017)
    In March 2017 the JTPF agreed the Report on the Use of Comparables in the EU. The report establishes best practices and pragmatic solutions by issuing various recommendations for both...
  8. Korea vs Corp, October 2001, Supreme Court, Case No 99두3423
    In Korea the tax authorities usually regarded domestic transactions as better comparables and there were only few cases where transfer pricing had been applied based on foreign transactions. In this...
  9. France vs. Microsoft, Feb 2012, CCA, No 10VE00752
    In the Microsoft case, the distribution activity of a French subsidiary of an American group was transferred to its Irish sister company. The French subsidiary was then converted into a...
  10. OECD COVID-19 TPG paragraph 33
    In general, there is no overriding rule on the inclusion or exclusion of loss making comparables in the OECD TPG.15 Accordingly, loss-making comparables that satisfy the comparability criteria in a...
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