Transfer Pricing Comparability Adjustments: The Pursuit of “Exact” Comparables

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.