TMI BlogTransfer Pricing Adjustments: Consistency Principle Inapplicable When TPO's Current Year Material Differs Significantly from Previous Year.Principle of consistency in Transfer Pricing adjustment - The material available with the TPO in the current year is vastly different to the material available with the TPO in the earlier year. In such circumstances, the principle of consistency does not hold water - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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