There is no systematic preference in the selection of one approach over the other, since in both cases reliable comparables can be obtained and even a combination of the two approaches can be used.
There are two types of comparables: internal comparables, which are generated from transactions between related and independent companies, and external comparables, which are transactions between independent companies.
The comparability analysis compares the circumstances of the related transactions with those of transactions between independent persons or entities that could be comparable.
In transactions between unrelated companies, market forces often determine the terms of commercial and financial relationships, whereas between related companies such forces may not directly affect prices.
Entities with consolidated worldwide net turnover exceeding 750 million euros are obliged to file Form 231 from the day following the end of the tax period to which the information to be supplied refers until the following twelve months.
The information contained in the documentation to be made available to the taxpayer in the event of a request from the Tax Agency, varies depending on the net turnover of the companies.