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Customer-specific premixing in nutritional product distribution requires functional comparability based on actual activities, not manufacturing labels.
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Transfer pricing comparability under Rule 10B depends on the actual functions performed, assets employed and risks assumed. Customer-specific dry blending of nutritional products, without chemical reaction, substantial transformation or emergence of a distinct product, can be an ancillary distribution function rather than a separate manufacturing segment. Plant and machinery or the accounting classification of products as finished goods are not conclusive. Applying manufacturing comparables to the entire distribution business may disregard the limited significance of incidental premixing. Functions and risks of marketing support services cannot automatically be attributed to distribution.
Transfer pricing comparability under Rule 10B depends on the actual functions performed, assets employed and risks assumed. Customer-specific dry blending of nutritional products, without chemical reaction, substantial transformation or emergence of a distinct product, can be an ancillary distribution function rather than a separate manufacturing segment. Plant and machinery or the accounting classification of products as finished goods are not conclusive. Applying manufacturing comparables to the entire distribution business may disregard the limited significance of incidental premixing. Functions and risks of marketing support services cannot automatically be attributed to distribution.
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