Arm's length price determination requires using the most appropriate transfer pricing method, with de minimis tolerance and safe harbour protections. Determination of arm's length price requires selecting and applying the prescribed most appropriate transfer pricing method based on transaction nature, class of transaction, class of associated enterprise, functions performed and other prescribed factors; a single price from that method is the arm's length price or, if multiple prices arise, their arithmetical mean is used. The actual transaction price is deemed arm's length if variation from the computed price falls within the prescribed de minimis tolerance. Income of one associated enterprise shall not be recomputed due to determination for another, deductions are restricted in respect of income enhanced by this computation, and the determination is subject to safe harbour rules.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Arm's length price determination requires using the most appropriate transfer pricing method, with de minimis tolerance and safe harbour protections.
Determination of arm's length price requires selecting and applying the prescribed most appropriate transfer pricing method based on transaction nature, class of transaction, class of associated enterprise, functions performed and other prescribed factors; a single price from that method is the arm's length price or, if multiple prices arise, their arithmetical mean is used. The actual transaction price is deemed arm's length if variation from the computed price falls within the prescribed de minimis tolerance. Income of one associated enterprise shall not be recomputed due to determination for another, deductions are restricted in respect of income enhanced by this computation, and the determination is subject to safe harbour rules.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
