OECD Guidelines Prevail

Tax Appeal Tribunal Supports Use of Interquartile Range Over Median

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The Tax Appeal Tribunal ruled in favor of taxpayers, endorsing the use of the interquartile range (IQR) for transfer pricing over the median value, in line with OECD guidelines.

This decision upholds the flexibility of OECD’s arm’s length principles and sets a precedent for similar future cases.

This alert details the Tribunal's decision to support the taxpayer's use of the interquartile range (IQR) over the tax authority's preference for a median adjustment, aligning with the OECD's guidelines on arm's length principles.

Click on the button below to download the alert.