Transactions with notified jurisdictional areas: enhanced transfer-pricing and deduction restrictions to curb tax avoidance measures. Transactions with parties in a notified jurisdictional area are treated as involving associated enterprises and certain transactions are deemed international transactions, bringing specified transfer-pricing and related provisions into application. Deductions for payments to financial institutions in such jurisdictions require a prescribed authorization enabling the tax authority to seek information; other expenditures require prescribed records. Sums received from persons in notified jurisdictions may be deemed income if source or beneficial ownership explanations are absent or unsatisfactory, and higher withholding obligations apply for payments to such persons.
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.
Transactions with notified jurisdictional areas: enhanced transfer-pricing and deduction restrictions to curb tax avoidance measures.
Transactions with parties in a notified jurisdictional area are treated as involving associated enterprises and certain transactions are deemed international transactions, bringing specified transfer-pricing and related provisions into application. Deductions for payments to financial institutions in such jurisdictions require a prescribed authorization enabling the tax authority to seek information; other expenditures require prescribed records. Sums received from persons in notified jurisdictions may be deemed income if source or beneficial ownership explanations are absent or unsatisfactory, and higher withholding obligations apply for payments to such persons.
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