Although there is no single way to carry out this process, it would be expected that there are quite a few similarities between the processes carried out by different professionals dedicated to transfer pricing analysis. price or margin) or if reasonably accurate adjustments can be made to eliminate the material effects of any such differences.”Īs with many transfer pricing concepts, making the aforementioned comparison may seem like a simple task, but in practice, it requires a deep understanding of the transaction to be analyzed and the identification of potential comparable transactions, which will determine the most appropriate method for conducting the analysis. Controlled and uncontrolled transactions are comparable if none of the differences between the transactions could materially affects the factor being examined in the methodology (e.g. “A comparison of a controlled transaction with an uncontrolled transaction or transactions.
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