Analysis of EXPORT FILTER used in Transfer Pricing

Abstract

In determination of ALP the main issue is to find the suitable comparables or closer comparables. The issue becomes more complex, when OECD and income tax guidelines do not indicate requirement of parameter, if any, to be applied to eliminate companies not having comparable business. The current research paper identifies certain parameters as filters and explores its efficacies in determining comparable companies to arrive at ALP. The research is done against the backdrop of OECD guidelines in this regards and attempts to justify that more than 50% than sales turnover can be considered as a filter required to effectively measure the comparability.