Related party by ownership despite restrictions on exercise ...
The Supreme Tax Court has held that internal or other restrictions on the excise of ownership rights do not obviate an association by common shareholding of more than 25%. It has also held that the application of the transfer pricing documentation rules to cross-border transactions only is, while discriminatory, justified by the need to protect tax revenue.
Kategorien: Supreme Tax Court cases
Schlagwörter: related party, transfer pricing, common ...
