Finally, given that that provision requires the appropriateness of the transfer pricing method chosen to be reasoned by the taxpayer and given the Decree's own express preference for the CUP method where comparable transactions are available (141), the absence of a best method rule does not relieve the tax administration from ensuring, before it agrees to the APA request, that the transfer pricing method selected by the taxpayer is able to provide for a reliable approximation of a market-based outcome in line with the arm's-length principle.
Remek, és az öné?eurlex-diff-2018-06-20 eurlex-diff-2018-06-20