International - Company Life Cycles in Database Analyses: An Approach for the Future?
- V. Trautmann
- International Transfer Pricing Journal, 2016 (Volume 23), No 6
- 4 November 2016
This article outlines an approach on how to enhance and simultaneously simplify economic analyses in a TNMM environment where commercial company databases are typically used to test the arm’s length nature of a group’s intercompany pricing. By using company life cycle stages derived from cash flow patterns as an additional quantitative screening criterion, this theoretically grounded approach is able to consider the typically unobservable OECD comparability criterion business strategies. In addition to offering better comparability and increased objectivity, this approach can contribute to a significant reduction of efforts linked to qualitative review steps and, therefore, compliance costs for the taxpayer.