Arm's length price must govern valuation of international transactions and cost allocations, subject to a non application carve out. Clause 105 provides that income or expense from an international transaction must be determined with regard to the arm's length price. It further requires ... Summary
Arm's length price must govern valuation of international transactions and cost allocations, subject to a non application carve out.
Clause 105 provides that income or expense from an international transaction must be determined with regard to the arm's length price. It further requires that allocation, apportionment or contributions to costs connected with benefits, services or facilities provided to associated enterprises be made with regard to the arm's length price where a mutual agreement exists and the provision involves an international transaction, but excludes application where such determination would reduce income chargeable to tax or increase the computed loss recorded in the books for that financial year.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 1
Join Channel
TaxTMI 
