Category Comparability

Comparability, Limited Risk Distributor, Profit Indicators, Tax Controversy

Misapplication of the Resale Price Method: LATAM Petroleum Distributor

Selecting alleged comparable companies with different functions than the tested party is known to open Pandora's Box in transfer pricing controversy, and is often exacerbated by a failure to adjust for material differences between the tested party and the selected comparables.

Harold McClure
February 23, 2021

Comparability, Limited Risk Distributor, Profit Indicators, TNMM/CPM

Comparability Issues Are a Slippery Slope in Transfer Pricing

Comparability is a key issue in transfer pricing that is often not fully appreciated. However, comparability issues are hardly uncommon in transfer pricing controversies and can create a trickle-down effect that leads to major taxation issues.

Harold McClure
December 14, 2020

Misapplication of the Resale Price Method: LATAM Petroleum Distributor

Comparability Issues Are a Slippery Slope in Transfer Pricing

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