The choice of the application of the RPM as an appropriate method also depends upon the identification of comparables and the completeness and accuracy of the available financial data for these comparables. The application of the RPM is particularly dependent upon similarity of functions performed, and ordinarily, the uncontrolled transactions should be selected from the distribution of goods within the same product categories. Among the closest external comparable companies identified, it was not possible to satisfy the degree of functional comparability necessary to apply the RPM.
For the above stated reasons, the RPM was not considered to be the most appropriate method for analyzing the covered transactions.