Transfer pricing benchmarking requires strict functional, product, and asset comparability while honoring binding administrative directives.
Transfer pricing benchmarking requires strict functional, product, and asset comparability while honoring binding administrative directives. Issue Whether transfer pricing adjustments, selection/exclusion of comparable entities, computation of operating margins, allocation of working capital, choice of benchmarking methods (TNMM vs. CUP vs. Berry Ratio), and disallowance of expatriate salaries can be sustained when facing functional dissimilarities, non-binding… Read More »