Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Export incentives directly connected with export activity are treated as operating income when computing the tested party's profit level indicator under the Transactional Net Margin Method. Excluding such incentives can distort the tested party's operating margin, particularly where incentives received by comparable companies are included in their operating income. The operating and arm's-length margins should therefore be recomputed after including eligible export incentives in the tested party's operating results.
Export incentives directly connected with export activity are treated as operating income when computing the tested party's profit level indicator under the Transactional Net Margin Method. Excluding such incentives can distort the tested party's operating margin, particularly where incentives received by comparable companies are included in their operating income. The operating and arm's-length margins should therefore be recomputed after including eligible export incentives in the tested party's operating results.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
