International - Transfer Pricing Comparability Adjustments: The Pursuit of “Exact” Comparables
- E. Muyaa
- International Transfer Pricing Journal, 2014 (Volume 21), No 5
- 12 September 2014
The author sets out comparability factors and other considerations in undertaking a comparability analysis, followed by a consideration of comparability adjustments and the challenges encountered with regard thereto, as well as the possible consequences of a lack of uniform guidance. Finally, the author considers the alternatives available to ensure that the arm’s length principle is upheld in a mutually beneficial manner for easy and effective compliance.