No transfer pricing adjustment for breaches of formality
The Supreme Tax Court has rejected a tax office assessment attempt on the basis of a hidden distribution of profits because of a delay in agreeing management charges in writing, saying that the double tax treaty related party provision bases the arm’s length standard on amount, rather than on the reason for, or documentation, of a transaction.
Kategorien: Supreme Tax Court cases
Schlagwörter: related party, transfer pricing, managem ...