Tag: Repeated analysis

TPG2022 Chapter III paragraph 3.5

/ Comparability analysis, Comparability analysis - 9 step process, Lack of comparables, Most appropriate method (MAM), OECD Transfer Pricing Guidelines (2022), Repeated analysis, TPG2022 Chapter III: Comparability Analysis
In practice, this process is not a linear one. Steps 5 to 7 in particular might need to be carried out repeatedly until a satisfactory conclusion is reached, i.e. the most appropriate method is selected, especially because the examination of available sources of information may in some instances influence the selection of the transfer pricing method. For instance, in cases where it is not possible to find information on comparable transactions (step 7) and/or to make reasonably accurate adjustments (step 8), taxpayers might have to select another transfer pricing method and repeat the process starting from step 4 ... Read more

TPG2017 Chapter III paragraph 3.5

/ Comparability analysis, Comparability analysis - 9 step process, Lack of comparables, Most appropriate method (MAM), OECD Transfer Pricing Guidelines (2017), Repeated analysis
In practice, this process is not a linear one. Steps 5 to 7 in particular might need to be carried out repeatedly until a satisfactory conclusion is reached, i.e. the most appropriate method is selected, especially because the examination of available sources of information may in some instances influence the selection of the transfer pricing method. For instance, in cases where it is not possible to find information on comparable transactions (step 7) and/or to make reasonably accurate adjustments (step 8), taxpayers might have to select another transfer pricing method and repeat the process starting from step 4 ... Read more