Transfer-pricing comparability for sourcing support services...

Transfer-pricing comparability for sourcing support services requires consistent application of the related-party transaction filter and exclusion of entities that fail it. Government-owned undertakings may not be suitable comparables where their ownership and control distinguish them from the tested party. A commission-based enterprise is not comparable with a cost-plus service provider because commission income depends on orders materialising, while cost-plus remuneration provides a mark-up on costs irrespective of sales. Project-management, infrastructure, engineering, architectural, and sector-specific consultancy services may also be functionally dissimilar to sourcing support services, requiring reassessment of the comparable set.