Transfer Pricing

This query is : Open

Querist : Anonymous

Querist : Anonymous (Querist)

12 January 2011 -How Many comparables can be use to determine ALP. I am using 21 comparables , It is justifiable or not.
-TP calculation is art to present that there are no any Tax evasion then why a TPO can arise objection against my ALP calculation.
-Which companies data can be used to determine ALP.
_I am using weighted averege method is justifiable.

Vivek Raju P

Vivek Raju P (Expert)
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12 January 2011 Yes normally the TPO takes any where between 15-20 comparables.

Again depends on the companies you use, must be of similar turnover, same industry segment, cost structure, operate in same geographical markets, same risk profile and such other things. What ever you take as a comparable needs to have adequate justification as to why it is a comparable and you need to demonstrate that.

Other opinions welcome

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Querist : Anonymous

Querist : Anonymous (Querist)

12 January 2011 thanks and I appreciate your opinion but Why company(comparables) will disclose to other his turnover, risk profile and such other things.

it may be possible that a company is using 15 Comparables and ALP may different if Company uses 20 Comparables then company will choose where ALP is in favour of company. are there any restriction
?

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