Comparability Adjustments. A Literature Review

Petutschnig, Matthias and Chroustovsky, Stefanie (2018) Comparability Adjustments. A Literature Review. WU International Taxation Research Paper Series, 2018-08. WU Vienna University of Economics and Business, Universität Wien, Vienna.


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This paper aims at providing a comprehensive overview of existing literature on the topic of comparability adjustments. Based on existing literature the most commonly used adjustments can be categorized in two broad categories: "accounting and financial risks adjustments" and "strategic/market adjustments". With the exception of working capital adjustments, the lack of guidance and recognized standardized application will quite possibly lead to continued discrepancies in their use. Taxpayers continue to struggle with the immense amount of documentation as well as justification requirements when it comes to adjustments, as there is no clear path to follow and very few practical application examples, which would unify the application of adjustments. As seen, even though the topic of comparability adjustments has been around since before the first version of the OECD TP Guidelines, the topic is yet to be fully explored in both official guidance as well as literature, research and especially practical tools.

Item Type: Paper
Additional Information: Editors: Eva Eberhartinger, Michael Lang, Rupert Sausgruber and Martin Zagler (Vienna University of Economics and Business), and Erich Kirchler (University of Vienna)
Keywords: Transfer Pricing, Comparability Adjustments, Arm's Length Principle
Classification Codes: JEL H25, H26, K34, G30, L20
Depositing User: Gertraud Novotny
Date Deposited: 19 Oct 2018 09:54
Last Modified: 29 Aug 2020 06:54


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