Comparability Analysis Under OECD Guidelines and Section 482

January 21, 2025 11:00 am (ET)

Arm’s length transfer pricing is based on comparability, but even the OECD Transfer Pricing Guidelines and US Sec. 482 regulations recognize that “perfect” comparables rarely, if ever, exist. Transfer pricing professionals must evaluate and measure comparability factors to determine whether they are material and, if differences exist, whether they can make a defensible adjustment. 

In this enlightening webinar, world-renowned transfer pricing economist Ednaldo Silva Ph. D. and Spencer Ho, a specialist at RoyaltyStat, an Exactera Company, discuss key elements of defensible comparability analysis. Join us to learn about the various factors that impact comparability and how to prioritize them, the importance of reliable data, and when and how to apply sound comparability adjustments.  

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Learning Objectives

Understand comparability from a transfer pricing and economic perspective

Learn how to approach a transfer pricing comparability analysis

Gain awareness of factors that can impact comparability according to the OECD and the IRS

Learn how to evaluate the materiality of comparability factors

Evaluate when comparability adjustments are needed

Understand the various types of comparability adjustments and how to apply defensible adjustments

Speakers

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Ednaldo Silva, Ph.D.

Ednaldo Silva, Ph.D., Senior Tax Economist at EdgarStat, is a leading transfer pricing expert with 30+ years of experience and founder of RoyaltyStat. As the IRS's first senior economic adviser, he played a key role in shaping the 1994 US transfer pricing regulations. Dr. Silva advises multinational corporations and law firms in high-profile cases, including a $3.4 billion GlaxoSmithKline settlement.

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Spencer Ho

Spencer Ho, RoyaltyStat Customer Success & Transfer Pricing Research Specialist at Exactera, specializes in training and assisting transfer pricing professionals in using RoyaltyStat and other databases to research transfer pricing issues and support their positions in compliance, audit, and controversy.