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Tribunal Adjusts Transfer Pricing: Alters Comparable Companies, Upholds Rejection of Foreign Entity as Tested Party.
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....TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated Enterprise as the tested party. The Tribunal upheld the transfer pricing adjustment but directed the exclusion of one comparable and the inclusion of another based on the arguments presented.....