Revenue Must Prove International Transaction Exists for AMP Expenses, Independent of Bright Line Test, per Chapter X.

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....TP adjustment - AMP expenses - the existence of an international transaction will have to be established de hors the BLT, the burden is on the Revenue to first show the existence of an international transaction. The objective of Chapter X is to make adjustments to the price of an international transaction which the AEs involved may seek to shift from one jurisdiction to another. An 'assumed' price cannot form the reason for making an ALP adjustment. - AT....