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Can the country-by-country report information be used to issue a transfer pricing assessment?


All information included in the CbC Report cannot be used to replace a detailed transfer pricing analysis of individual transactions and prices based on a fully functional analysis and a full comparability analysis. The information in the CbC Report on its own does not constitute conclusive evidenc​e that transfer prices are or are not proper.​​
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Last Update: 04 Sep 2020 06:06 PM Saudi Arabia Time