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Internal comparables under the transactional net margin method should generally be preferred to external comparables where audited segmental accounts reliably distinguish associated-enterprise and non-associated-enterprise transactions. Segmental financials extracted from audited accounts may support arm's length price determination where a chartered accountant certifies both their mathematical accuracy and allocation on a generally accepted rational basis. A claim that segmental data were not maintained is unsustainable when the relevant segmental figures are demonstrably derived from audited accounts.
Internal comparables under the transactional net margin method should generally be preferred to external comparables where audited segmental accounts reliably distinguish associated-enterprise and non-associated-enterprise transactions. Segmental financials extracted from audited accounts may support arm's length price determination where a chartered accountant certifies both their mathematical accuracy and allocation on a generally accepted rational basis. A claim that segmental data were not maintained is unsustainable when the relevant segmental figures are demonstrably derived from audited accounts.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
