Transfer Pricing Adjustments: Use Operating Profit, Not Net Profit, for TNMM Comparisons in International Transactions.

Transfer Pricing Adjustments: Use Operating Profit, Not Net Profit, for TNMM Comparisons in International Transactions. https://www.taxtmi.com/highlights?id=34531 TPA - 'operating profit’ from the international transaction is compared with the operating profit margin of the comparables under the TNMM. Thus the addition based on the transfer pricing adjustment, on the strength of `net profit’ as numerator in contrast to `operating profit’, cannot be upheld - AT en-us Thu, 27 Apr 2017 11:23:48 +0530 Thu, 27 Apr 2017 11:23:48 +0530 TaxTMI RSS Generator Transfer Pricing Adjustments: Use Operating Profit, Not Net Profit, for TNMM Comparisons in International Transactions. https://www.taxtmi.com/highlights?id=34531 TPA - 'operating profit’ from the international transaction is compared with the operating profit margin of the comparables under the TNMM. Thus the addition based on the transfer pricing adjustment, on the strength of `net profit’ as numerator in contrast to `operating profit’, cannot be upheld - AT Highlights Income Tax Thu, 27 Apr 2017 11:23:48 +0530 https://www.taxtmi.com/highlights?id=34531