Transfer pricing ensures international transactions are measured at arm's length to prevent profit shifting and tax base erosion. Transfer pricing regulates prices charged between associated enterprises across jurisdictions and requires that income from international transactions be computed having regard to the arm's length price, creating a statutory framework to ensure reasonable profit allocation and to prevent diversion of profits and erosion of the domestic tax base through intra group transactions.
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Provisions expressly mentioned in the judgment/order text.
Transfer pricing ensures international transactions are measured at arm's length to prevent profit shifting and tax base erosion.
Transfer pricing regulates prices charged between associated enterprises across jurisdictions and requires that income from international transactions be computed having regard to the arm's length price, creating a statutory framework to ensure reasonable profit allocation and to prevent diversion of profits and erosion of the domestic tax base through intra group transactions.
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