Taxpayers can employ a different method of transfer pricing in accordance with Article 9 of Transfer Pricing Bylaws if:
Methods mentioned in Article 7 of Transfer Pricing Bylaws are inconsistent
The alternative method proves to be more accurate and relevant to arm’s length price following the facts and conditions of the transaction given that the alternative method meets the terms and conditions of Article 6 of the Transfer Pricing Bylaws
The burden of proving that the two conditions are satisfied lies on the taxpayer.
