Arm's length price determination: selection, notice, evidence, and time limits govern transfer pricing officer procedures and reporting. The Transfer Pricing Officer may select any international transaction under a Board-framed risk management strategy, notify the assessee and Assessing ... Summary
Arm's length price determination: selection, notice, evidence, and time limits govern transfer pricing officer procedures and reporting.
The Transfer Pricing Officer may select any international transaction under a Board-framed risk management strategy, notify the assessee and Assessing Officer, require attendance or documents, consider evidence after hearing, and determine arm's length price under prescribed powers; absent cooperation, the TPO may determine price to the best of his judgment. Determinations and reports must be served within a statutory outer time limit, and the Board's risk management strategy is not disclosable to assessees or the public.
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