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Transfer pricing comparables for software-development and...
Transfer pricing comparability excludes functionally different providers and companies whose abnormal profits from extraordinary circumstances distort pricing.
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Transfer pricing comparables for software-development and IT-enabled services must be assessed for functional similarity. Substantially outsourced operations differ from in-house service models, while higher-end knowledge process outsourcing is not functionally comparable to routine IT-enabled or business process outsourcing services when determining arm's length prices using profit level indicators. Comparables with abnormal profits caused by extraordinary circumstances must be excluded where their inclusion would distort the mean profit level indicator. Excluding individual companies selected through filters is distinct from directing the use of filters or a fresh comparability exercise.
Transfer pricing comparables for software-development and IT-enabled services must be assessed for functional similarity. Substantially outsourced operations differ from in-house service models, while higher-end knowledge process outsourcing is not functionally comparable to routine IT-enabled or business process outsourcing services when determining arm's length prices using profit level indicators. Comparables with abnormal profits caused by extraordinary circumstances must be excluded where their inclusion would distort the mean profit level indicator. Excluding individual companies selected through filters is distinct from directing the use of filters or a fresh comparability exercise.
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