1 Determination of years to be covered

2 Analysis of taxpayer’s circumstances

3 Understanding of controlled transaction based on functions, assets and risks

4 Review of internal comparables (if any)

5 Identifying sources for external comparables (if any)

6 Selection of the most appropriate method and net profit indicator

7 Identification of potential comparables

8 Determination of and making comparability adjustments

9 Interpretation and use of data collected, determination of arm’s length price