under which method, ALP shall be Average of all values, irrespective of number of entries in dataset. variation is 5%.
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Quick Summary
This discussion clarifies the application of the Comparable Uncontrolled Price (CUP) method in transfer pricing. It highlights that the Average of all values is used for ALP unless there are six or more data entries, in which case the 35th to 65th percentile range applies. This percentile rule is specific to the CUP method, with other methods allowing for different approaches.