In determining this point, where the range comprises results of relatively equal and high reliability, it could be argued that any point in the range satisfies the arm’s length principle. Where comparability defects remain as discussed at paragraph 3.57, it may be appropriate to use measures of central tendency to determine this point (for instance the median, the mean or weighted averages, etc., depending on the specific characteristics of the data set), in order to minimise the risk of error due to unknown or unquantifiable remaining comparability defects.
TPG2017 Chapter III paragraph 3.62
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Arm’s length range, Central tendency, Comparability analysis, Comparability defects, Interquartile range (IQR), Mean, Mean Weighted averages, Median, Weighted averages
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