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Study on comparable data used for transfer pricing in the EU

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  • Deloitte

Abstract

This study aims at providing an overview and assessment of the availability and quality of market data ('comparables') used for transfer pricing purposes and, more specifically comparable searches under the Comparable Uncontrolled Price (‘CUP’) method and under the Transactional Net Margin Method (‘TNMM’)in the EU-28 Member States. More specifically, the study covers the following aspects: Assessing and evaluating situations characterising the lack and / or non-reliability of comparable data; Assessing and evaluating the situation for pan-European comparable searches ; Developing and envisaging EU-tailored solutions and possible adjustments taking into consideration some advantages and assets offered by the EU internal market ; Contribute to strengthening and effectively implementing an improved EU transfer pricing framework and fight against aggressive tax planning.

Suggested Citation

  • Deloitte, 2016. "Study on comparable data used for transfer pricing in the EU," Taxation Studies 0070, Directorate General Taxation and Customs Union, European Commission.
  • Handle: RePEc:tax:taxstu:0070
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    File URL: https://publications.europa.eu/en/publication-detail/-/publication/d16d2635-c685-11e6-a6db-01aa75ed71a1
    File Function: final version, 2016
    Download Restriction: no
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    More about this item

    Keywords

    European Union; taxation; transfer pricing;
    All these keywords.

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods

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