New Draft Rules Introduce "Range Concept" for Arm's Length Price in Transactions; Stakeholder Feedback Due May 31, 2015.

The draft scheme outlines proposed rules for computing the Arm's Length Price (ALP) for international or specified domestic transactions from April 1, 2014. It introduces the "range concept" for determining ALP using methods like Transactional Net Margin Method, Resale Price Method, or Cost Plus Method, requiring at least nine comparable entities with three-year data. If the transfer price falls outside the 40th to 60th percentile range, the median is used as ALP. Multiple year data is mandatory for these methods, with allowances for two-year data in specific cases. The arithmetic mean remains applicable when the range concept does not apply. Stakeholder feedback is invited by May 31, 2015.

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