Authors: Piergiorgio Valente, Antonella della Rovere and Pietro Schipani

The possibility that related companies belonging to the same multinational Group may pursue policies aimed at affecting transfer prices has prompted supranational bodies to draft a series of guidelines concerning the identification of the so-called arm's length value of intercompany transactions, and taking into account the proper mechanisms for comparisons and assessments. The comparability analysis is of fundamental importance in any transfer pricing analysis; it must be performed to assess how the intragroup transactions under review were carried out and to prove, by means of a comparison with similar transactions carried out by independent parties, that the tested party’s prices respected the arm’s length principle.

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