OECD Guidelines 2022 — what changed for benchmarking
Chapter II refinements, financial transactions Chapter X, simplified approach for low-value-adding services.
Knowledge base.
BEPS Action 13 — Local File & Master File essentials
Three-tiered documentation, materiality thresholds by jurisdiction, CbCR overlap.
TNMM in practice — choosing the right PLI
When to use operating margin vs Berry Ratio vs markup on total costs.
Defending an interquartile range
Three-year weighted average, loss-makers, persistent loss test, statistical adjustments.
Comparable search strategy
Universe → screening → qualitative review → final set. The audit-proof workflow.