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Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmarking.
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Prior-period expenditure is allowable where the liability, including its particulars and quantum, became known and ascertainable only in the relevant year; invoices may be recorded on crystallisation notwithstanding that the underlying expenditure relates to an earlier period. Transfer-pricing analysis must separately benchmark functionally distinct consulting and captive back-office divisions where their functions, methods and economic profiles differ. Entity-level aggregation is unsustainable in those circumstances, supporting deletion of the related adjustment.
Prior-period expenditure is allowable where the liability, including its particulars and quantum, became known and ascertainable only in the relevant year; invoices may be recorded on crystallisation notwithstanding that the underlying expenditure relates to an earlier period. Transfer-pricing analysis must separately benchmark functionally distinct consulting and captive back-office divisions where their functions, methods and economic profiles differ. Entity-level aggregation is unsustainable in those circumstances, supporting deletion of the related adjustment.
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