Tag: Comparable uncontrolled transaction

A comparable uncontrolled transaction is a transaction between two independent parties that is comparable to the controlled transaction under examination. It can be either a comparable transaction between one party to the controlled transaction and an independent party (“internal comparable”) or between two independent parties, neither of which is a party to the controlled transaction (“external comparable”).

France vs. PHARMATIQUE INDUSTRIE, July 1994, CAA, No 92PA01392

France vs. PHARMATIQUE INDUSTRIE, July 1994, CAA, No 92PA01392

The Pharmatique Industrie case shows the high comparability standard required by the courts of France. The tax authorities used five similar products, distributed by three companies operating in the same pharmaceutical sector, as comparables in a transfer pricing dispute. Click here for translation Société Pharmatique Industrie, July 1994, CCA, No 92PA01392 ... Continue to full case