In our last article on the fundamentals of entity characterization in transfer pricing documentation (TPD), we highlighted the concept that our knowledge of the nature of a particular business determines the entity characterization and in turn, the entity characterization influences the direction and tone of the TPD as well as setting the direction in having a meaningful comparison of the price or level of income of the entity in a controlled transaction against the price or level of return from similar independent transactions.
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What’s #TRENDING? Understanding and documenting industry analysis
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Fundamentals of entity characterization in TPD
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How much do you know about your family member, a friend, a colleague, or a significant other? Is your characterization of a person reflective of his or her real character? Does your characterization of a person affect how you deal with the person?