求高手翻译啊，在线等！！！ 不要翻译器翻译的

The deployment of profit-based TPM (e.g. Comparable Profit Method, CPM, and Profit Split Methods) with the use of profit level indicators (e.g. return on capital employed or certain financial ratios) and the determination of a —profit margin range“ (normally the interquartile range) of identified arm‘s length comparables have been sought to bypass these shortcomings of the ALP.Profit-based TPMs compare the profit margin of the tested party (related party) with an interquartile range of corresponding profit margins of unrelated parties. Not the transaction-based margin but the company‘s profit margin is considered with the result that a CPM turns into a transaction-based Transactional Net Margin Method (TNMM) if the tested party only performs one related-party transaction. Generally, whether the ALP is met is then derived indirectly by the
assessment as to whether the profit margin of the test party falls in the comparable benchmark range.
Like transaction-based TPMs, deploying profit-based TPMs for arm‘s length tests is limited by the availability of comparable data. Lacking any solution to this limited availability of comparable data in an international context, taxpayers and tax authorities spend incredible resources to identify comparable data, or to develop comparable data, for testing the related parties‘ margin or other profit level indicators in order to assess whether the taxpayer met the ALP. Notwithstanding the non-comparability problem (e.g. for value chain issues), while databases are fairly available in the US and Canada and various European countries, there is generally a huge lack of comparable data for transfer pricing purposes in other OECD countries and, even more importantly, in transition and emerging countries (China,India,Malaysia, Brazil, Russia), let aside the situation in developing countries.