1. The selection of a transfer pricing method always aims at finding the most appropriate method for a particular case. However, in evaluating the choice of method for in-scope transactions, it is neither necessary to prove that a particular method is not suitable under the circumstances, nor is it necessary that all transfer pricing methods should be analysed in depth or tested in each case in selecting the most appropriate method.1
2. Based on the economically relevant characteristics of in-scope transactions and the information available on comparable uncontrolled transactions, the transactional net margin method is chosen as the most appropriate method under the simplified and streamlined approach.
3. However, it is recognised that there may be instances (although these may be rare, as the distribution of commodities is excluded from scope) where the application of the comparable uncontrolled price method using internal comparables could be potentially more appropriate to apply to price in-scope transactions. For those instances, for transactions within the scope of the simplified and streamlined approach, an exception is provided that allows that the comparable uncontrolled price method using internal comparables can be used to reliably price in-scope transactions where that is in accordance with Part II B of Chapter II and A.4.2. of Chapter III of these Guidelines and both the comparables and any information utilised to determine that the application of the comparable uncontrolled price method is more appropriate are readily available to tax administrations and taxpayers.