The landscape of Transfer Pricing litigation delves around matters that are more or less factual, viz. selection of most appropriate method, choice of comparable companies, aggregation of international transactions, etc. Among the various issues cited, one of the most common litigative issues is the selection of comparable companies. It is pertinent to note that the selection of comparable companies is a dynamic and statistical process (conducting a search, including the application of quantitative and qualitative filters) that requires judgment, and the same cannot be bracketed as a formula that would yield the same results every time it is run or processed as the qualitative aspect is more subjective in nature.
