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Transfer pricing comparability under Rule 10B requires a...
Transfer pricing comparables must reflect functional similarity, with diverse activities and asset profiles supporting exclusion from contract service comparisons.
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Transfer pricing comparability under Rule 10B requires a factual, data-driven assessment of functional similarity. A company with diverse functions, significant tangibles and inventories can be functionally dissimilar to a contract service provider and excluded as a comparable. Review of a comparability finding considers whether irrelevant material was taken into account, relevant material was overlooked, or the finding was perverse. Functional differences and asset profiles are therefore relevant to the selection of comparables.
Transfer pricing comparability under Rule 10B requires a factual, data-driven assessment of functional similarity. A company with diverse functions, significant tangibles and inventories can be functionally dissimilar to a contract service provider and excluded as a comparable. Review of a comparability finding considers whether irrelevant material was taken into account, relevant material was overlooked, or the finding was perverse. Functional differences and asset profiles are therefore relevant to the selection of comparables.
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