Precise definition of the operation in the transfer pricing comparability analysis

Abstract

PROBLEM: transfer pricing arises from the development of large multinational companies, whose purpose is to protect the tax base of the different tax jurisdictions, setting prices among a group of companies and obtaining growth opportunities internationally, the problem to be dealt with in the This investigation lies in the search for comparables, due to the manipulation of prices made by said companies, which affects the correct determination of the tax base and affects the control for the tax administrations. OBJECTIVE: the main objective of this research is to analyze the procedure to precisely define the operation as an important step in the transfer pricing comparability analysis. METHOD: the research is of a qualitative type, observation techniques were used, participation in virtual seminars, taught by experts in Transfer Pricing that are part of the Organization for Economic Cooperation and Development and the Inter-American Center of Tax Administrations and documentary research. RESULTS: delimiting or precisely defining the related transaction is useful to determine whether or not a transfer price is consistent with the arm's length principle. CONCLUSION: once the operation is defined, the selection of the most appropriate method will be even easier and will allow the transfer prices to be objectively evaluated.