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in (Malaysian) IRBM Transfer
Pricing Guideline 2012
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Cases
applicable: used
only when traditional methods cannot be reliably applied or exceptionally
cannot be applied at all
Similar to the cost
plus and resale price methods in the sense that it uses the margin approach
which examines the net profit margin relative to an appropriate base such as
costs, sales or assets attained by the MNE from a controlled transaction.
Since net margins
(unlike gross margins or prices) tend to be significantly influenced by various
factors other than products and functions (e.g. competitive position, varying
cost structures, differences in cost of capital etc), it is stressed that usage
of TNMM be confined to cases where functions have a high degree of similarity,
so as to eliminate the effects of these other factors.
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