Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking methods.

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....Transfer-pricing treatment of advertisement, marketing and promotion expenditure requires evidence of an arrangement obligating expenditure for an associated enterprise's brand promotion; disclosed marketing reimbursements alone do not create a separate international transaction. Accordingly, AMP adjustments based on the Bright Line Test or intensity-based TNMM were deleted. Comparable selection must reflect functional similarity, with service providers excluded from a predominantly trading-based networking segment and manufacturing comparables adjusted or verified where required. Royalty integral to manufacturing may be aggregated under TNMM where reliable CUP comparables are unavailable, avoiding double adjustment. For low-risk equipment .........