Where a cost based method is determined to be the most appropriate method to the circumstances of the case, the analysis would require examining whether the costs incurred by the group service provider need some adjustment to make the comparison of the controlled and uncontrolled transactions reliable.
TPG2017 Chapter VII paragraph 7.33
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Cost plus method, Intra-group services, Service fee, Services
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