What people are saying - Write a review
We haven't found any reviews in the usual places.
Introduction and Summary of Rules
lan R Phillips
17 other sections not shown
accepted additional equity investment allocated amount allocation of income allowed annual royalty apply arm's length price arm's length principle assessment Belgium Brazil Canada Canadian tax authorities capital charge competent authority provisions connection with S's contract corporation correlative adjustment cross-border transactions deduction Denmark different countries dividend domestic double taxation Finland foreign subsidiary foreign tax credits Hong Kong imputed income and expenses income tax Independent determination land and warehouse located in different manufacturers located mutual agreement procedure non-resident normally OECD P's executives P's intangibles parent company parties at cost payment promotional expense related companies related parties Remains a loan research and development resident Revenue review S's operations rules S's country sells these products separate determination services in connection shareholder specific statute of limitations subject to withholding tax avoidance tax consequences tax haven tax law tax purposes tax rates tax treaties taxable income taxpayer transfer pricing visits by P's withholding tax Zealand