(i) the correct application of the most appropriate method for the determination of transfer prices can lead to obtaining, instead of a single value, a range of values which all comply with the arm’s length principle;
(ii) in this case, it is possible to consider the entire range of values within the arm’s length range (so-called “full range”) if all the transactions identified in the range are equally comparable;
(iii) on the other hand, if some of the transactions included in the range should present comparability defects that cannot be reliably identified or quantified and, therefore, rectified, it is preferable to use “statistical methods” (in order to strengthen reliability) and a value in the narrow range between the first and third quartiles;
(iv) It is responsibility of the Revenues Agency to justify the identification of a specific point within the range that best satisfies the arm’s length principle;
(v) The use of a value that is as central as possible must be limited to cases in which the range does not include values characterized by a sufficient degree of comparability and, also in this case, must be specifically motivated.
