Answer:
The correct answer is D. Best method.
Explanation:
As a result of the BEPS Action Plan, as well as the Report on Actions 8 through 10 called “Ensure that the results of transfer prices are in line with the creation of value,” some considerations on the application of the CUP to transactions involving raw materials, commodities or commodities. These considerations were included in the 2017 update of the OECD Guidelines. In this sense, the update of the guidelines apart from establishing certain recommendations for their application, confirms that the CUP is generally the most appropriate method to establish the price of free competition in the transfer of commodities.
Despite the observed evolution of the OECD Guidelines in relation to traditional transactional methods, the increasing integration of multinational companies has made the identification of comparable transactions more difficult, making the application of these methods less common and opening the door to the application of methods based on profitability, without detriment of carrying out the due process of evaluation of the method that best applies to the analysis of the specific taxpayer transaction.