Arm's length price defined as price between non-associated enterprises in uncontrolled conditions, guiding transfer pricing determinations. The section defines arm's length price as the price in transactions between non-associated enterprises in uncontrolled conditions and sets that concept as central to transfer pricing determinations. It defines enterprise to cover persons and permanent establishments engaged in production, IP rights, services, contract work, investment or securities dealings, including activities through units or subsidiaries; permanent establishment is a fixed place of business. It also prescribes specified date for filing and treats transaction broadly to include formal or informal arrangements or concerted actions.
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 defined as price between non-associated enterprises in uncontrolled conditions, guiding transfer pricing determinations.
The section defines arm's length price as the price in transactions between non-associated enterprises in uncontrolled conditions and sets that concept as central to transfer pricing determinations. It defines enterprise to cover persons and permanent establishments engaged in production, IP rights, services, contract work, investment or securities dealings, including activities through units or subsidiaries; permanent establishment is a fixed place of business. It also prescribes specified date for filing and treats transaction broadly to include formal or informal arrangements or concerted actions.
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