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Transfer-pricing benchmarking for administrative and marketing...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and margin issues.
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Transfer-pricing benchmarking for administrative and marketing support services requires functional similarity and adequate segmental data. Engineering consultancy, construction-related activities, trading and mixed sales-service operations, commission agency and technical services are unsuitable comparables; a different financial year alone does not require exclusion where an appropriate adjustment is possible. For IT-enabled services, outsourcing businesses without segmental information and knowledge-process outsourcing providers are functionally dissimilar. Proposed comparables needing review of segmental or financial data, including those affected by a service-income filter, require verification and fresh computation. Claimed comparable-margin corrections and risk adjustments depend on substantiation, factual reconciliation and consequential examination.
Transfer-pricing benchmarking for administrative and marketing support services requires functional similarity and adequate segmental data. Engineering consultancy, construction-related activities, trading and mixed sales-service operations, commission agency and technical services are unsuitable comparables; a different financial year alone does not require exclusion where an appropriate adjustment is possible. For IT-enabled services, outsourcing businesses without segmental information and knowledge-process outsourcing providers are functionally dissimilar. Proposed comparables needing review of segmental or financial data, including those affected by a service-income filter, require verification and fresh computation. Claimed comparable-margin corrections and risk adjustments depend on substantiation, factual reconciliation and consequential examination.
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