Other net profit indicators may be appropriate depending on the facts and circumstances of the transactions. For instance, depending on the industry and on the controlled transaction under review, it may be useful to look at other denominators where independent data may exist, such as: floor area of retail points, weight of products transported, number of employees, time, distance, etc. While there is no reason to rule out the use of such bases where they provide a reasonable indication of the value added by the tested party to the controlled transaction, they should only be used where it is possible to obtain reliable comparable information to support the application of the method with such a net profit indicator.
TPG2017 Chapter II paragraph 2.105
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Denominator - employees, Diagnostic ratios, Profit Level Indicator (PLI), Transactional net margin method (TNMM), Transactional profit method, Transfer pricing methods
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