Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivables.

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....Transfer pricing requires selection of the most appropriate method based on transaction nature and comparable-data reliability, with neither CUP nor TNMM having statutory priority. An external CUP based on an associated enterprise's purchases from independent suppliers may be reliable where geographic, volume or timing differences do not materially affect price or can be reasonably adjusted. TNMM may be unreliable without meaningful adjustment for abnormal fixed costs from low capacity utilisation. Foreign-currency borrowings and receivables require currency-specific benchmarking under comparable uncontrolled conditions. Delayed export receivables constitute separate international transactions, with interest benchmarked at LIBOR plus 200 basis points after a 60-day credit period.....