Make comparability do the work
Apply comparability factors to evaluate whether uncontrolled data can reliably test a controlled transaction.
Comparability is the bridge between the controlled transaction and the market evidence. The five checks Use five questions as a habit: What is being transferred? What functions are performed? What do the contracts say? What market conditions apply? What business strategy changes the economics? Reliability depends on the method A direct price method needs tighter product and terms comparability. A net-margin method may allow broader product differences, but it still needs functional similarity and a sensible profit-level indicator. Adjust or reject If a difference materially affects price or profit and you can adjust it reliably, document the adjustment. If you…
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