Transfer-pricing analysis of spare replacement services depends...

Transfer-pricing analysis of spare replacement services depends on the entity's actual functions rather than its formal designation. A business that merely supplies and holds spares under an associated enterprise's directions, without control over customers or resale prices, is characterised as a captive service provider rather than a trader. That functional characterisation supports use of the transactional net margin method with appropriate comparables to determine arm's length price, instead of the resale price method. The discussion addresses the distinction between TNMM and RPM where resale functions and pricing control are absent.