COMPARABILITY ANALYSIS IN TRANSFER PRICING: Application Methods

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COMPARABILITY ANALYSIS IN TRANSFER PRICING: Application Methods

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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TRANSFER PRICING MANUAL (2nd Ed.)

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TRANSFER PRICING MANUAL (2nd Ed.)

Author: Piergiorgio Valente

The “Transfer Pricing Manual” (II Edition, pp. 3400) is a helpful tool that provides professionals and scholars with accurate and rigorous answers – from both, a legal-economic perspective as well as a hands-on approach – on complex issues involving intercompany transfer prices.
The Manual examines the Transfer Pricing topic in detail, by focusing on the most significant aspects. In particular, it provides an analytical picture that thoroughly reviews transfer pricing regulations in addition to all other information that might be necessary as a helpful guideline regarding operating issues that might derive from the application thereof. From this perspective, the Volume addresses both those who have to deal with the subject for academic and/or didactic purposes as well as those who are faced with problem-solving issues within a technical-professional context.
This second edition has the special feature to delve into certain specific themes that are treated comprehensively with respect to the first edition.
The text affords an in-depth examination of themes such as Transfer Pricing documentation duties pursuant to Italian legislation, Transfer Pricing regime proposals in developing Countries, EC and international procedures for settling international controversies, procedures relating to the determination of income allocation to PEs, intercompany loans, Transfer Pricing determination methods, intangibles, intercompany services, functional and comparability analyses as well as CCCTB.

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