Equivalent value attachment under money laundering law upheld where received funds were treated as proceeds of crime and prior-acquired property could...
TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated Enterprise as the tested party. The Tribunal upheld the transfer pricing adjustment but directed the exclusion of one comparable and the inclusion of another based on the arguments presented.
TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated Enterprise as the tested party. The Tribunal upheld the transfer pricing adjustment but directed the exclusion of one comparable and the inclusion of another based on the arguments presented.
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