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Transfer Pricing Adjustments Must Use External Comparables to Validate Internal Figures for Compliance and Accuracy.
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....Transfer pricing adjustment - primary responsibility to bench mark the transactions with comparable cases - the certificate issued by the auditors only spell out the percentage of overheads over the revenue and hence it is only a factual aspect of internal figures. In Transfer pricing study, what is required to be done is to validate the said claim with an external comparable. - AT....
TaxTMI
TaxTMI