Transfer-pricing studies for software development services...

Transfer-pricing studies for software development services cannot be rejected merely because comparability filters require modification when the taxpayer's functions, assets, risks, contractual terms, tested-party selection, databases and search keywords remain undisputed. Modified filters should instead be applied to the identified database, with the accept/reject matrix reviewed and functionally unsuitable comparables excluded before determining the arm's-length price. Interest on delayed associated-enterprise receivables is a separate international transaction where it is not aggregated with transactional net margin method margins after a working-capital adjustment; receivables and payables cannot be set off. The software-development arm's-length price and consequential delayed-receivables adjustment were restored for fresh consideration.