A campaign is building for the introduction of the inter-quartile range, and the acceptance of multiple year data, for transfer pricing documentation in India – a country that goes against the global best practice. Indian transfer pricing regulations are unique in the sense they require the computation of a single arm’s-length price, through the mean of comparables, instead of a range. Tax practitioners are not interested in being unique though. Sophie Ashley finds out why.
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Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default