Tax Newsletter May 2023 – Deloitte

Global Profitability Analysis – Considerations for the application of the arm’s length principle:
As a general rule, the transactions subject to transfer pricing must be analyzed transaction per transaction.
In certain circumstances, taxpayers may find themselves limited when performing an individual transfer pricing analysis on an intercompany transaction. In such cases, and to the extent that these are fully justified, it may be necessary to apply a global profitability analysis.