TPO to Exclude Local Vendor Deals from ALP Assessment; Focus on Associated Enterprises for Transfer Pricing Adjustments.

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Full Text of the Document

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....TP Adjustment - determination of arm’s length price, ALP - Transactions with the local vendors the terms of which are not influenced by Comer SpA cannot be treated as deemed international transaction and accordingly cannot be included for the purpose of ALP adjustment. TPO is directed accordingly to consider only the transaction with AE for the purpose of determination ALP - AT....