The most boring paragraph in the most boring book in the world

 “The process followed to identify potential comparables is one of the most critical aspects of the

comparability analysis and it should be transparent, systematic and verifiable. In particular, the

choice of selection criteria has a significant impact on the outcome of the analysis and should

reflect the most meaningful economic characteristics of the transactions compared. Complete

elimination of subjective judgements from the selection of comparables would not be feasible,

but much can be done to increase objectivity and ensure transparency in the application of

subjective judgements. Ensuring transparency of the subject may depend on the extent to which

the criteria used to select potential comparables are able to be disclosed and the reasons for

excluding some of the potential comparables are able to be explained. Increasing objectivity and

ensuring transparency of the process may also depend on the extent to which the person

reviewing the process (whether taxpayer or tax administration) has access to information

regarding the process followed and to the same sources of data. Issues of documentation of the

process of identifying comparables are discussed in Chapter V.”  (See Note below)

I have double spaced this to reduce concentration levels and make it easier to read!

Own up!  It is true is it not, that once you get to the end of the paragraph you have no idea what they are trying to say, even if you read it a second or third time, without falling asleep.

Note: Chapter 111, Paragraph A.5.3.46, Page 162, OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations’, January 2022