Comparability Adjustments A Literature Review

20 Pages Posted: 18 Oct 2018

See all articles by Matthias Petutschnig

Matthias Petutschnig

Vienna University of Economics and Business

Stefanie Chroustovsky

Vienna University of Economics and Business

Date Written: October 1, 2018

Abstract

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.

Keywords: Transfer Pricing, Comparability Adjustments, Arm´s Length Principle

JEL Classification: H25, H26, K34, G30, L20

Suggested Citation

Petutschnig, Matthias and Chroustovsky, Stefanie, Comparability Adjustments A Literature Review (October 1, 2018). WU International Taxation Research Paper Series No. 2018-08. Available at SSRN: https://ssrn.com/abstract=3266107 or http://dx.doi.org/10.2139/ssrn.3266107

Matthias Petutschnig (Contact Author)

Vienna University of Economics and Business ( email )

Welthandelsplatz 1
Building D 3
Vienna, Wien A-1020
Austria

HOME PAGE: http://www.wu.ac.at

Stefanie Chroustovsky

Vienna University of Economics and Business ( email )

Welthandelsplatz 1
Vienna, Wien 1020
Austria

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