Market leading insight for tax experts
View online issue

Transfer pricing: comparables under attack

Are all comparables, like snowflakes, different?

No two snowflakes are the same

Are all comparables like snowflakes different? Just like snowflakes at the superficial level the comparables may look alike but if you try to go down to the molecular level they begin to look different. The challenge ‘no two snowflakes are the same ’ begins to resonate with the task of finding comparables sufficiently similar to the tested party to provide reliable support for the arm’s-length principle.

Comparables are under attack because as one digs deeper than the superficial level of comparability differences emerge in the superficial similarities.

Is it always necessary to move away from the superficial level of comparability?

If all you need to know is whether the snow is at an acceptable level to wear shoes rather than boots and there is a pretty universal understanding...

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top