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Is there any preference for the application of local comparable data with regard to comparability analyses? Can foreign comparable data be applied?

Local comparable data is favored. However, following Article 13 (C) of the Transfer Pricing Bylaws, GAZT may permit the application of foreign comparable data in case of absence of local comparables. In such event, taxpayers must be able to illustrate to GAZT that foreign comparable data is compatible with set requirements in Chapter 3 of the Transfer Pricing Bylaws, and will take into account the anticipated impact of geographic differentiation and other relevant factors.​​