Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
Determining arm’s length price adjustment - part of loan was subsequently converted into equity. To the extent of loan converted into equity, no transfer pricing adjustment is required with effect to the date of such conversion - AT
Determining arm’s length price adjustment - part of loan was subsequently converted into equity. To the extent of loan converted into equity, no transfer pricing adjustment is required with effect to the date of such conversion - AT
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