Argument (#06 June 2016)

Sources of Information for Transfer Pricing

Sources of information are a key pillar of transfer pricing (TP) legislation taking into account the fact that relevant data strongly affects the conclusion on comparability and, hence, choice of applicable TP method. Current TP legislation requires strong comparability of transactions to consider not only basic issues like subject matter, delivery terms and payment terms but also second-tier issues like market conditions, business strategy of the counterparties and so on that as a matter of practice strongly prevent taxpayers from conclusion about comparability...

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