TPG2022 Chapter VI paragraph 6.205

« | »

Where the tested party does not use unique and valuable intangibles, and where reliable comparables can be identified, it will often be possible to determine arm’s length prices on the basis of one-sided methods including the CUP, resale price, cost plus and TNMM methods. The guidance in Chapters I – III will generally be sufficient to guide the determination of arm’s length prices in such situations, without the need for a detailed analysis of the nature of the intangibles used by the other party to the transaction.

Related Guidelines