Post by account_disabled on Mar 14, 2024 8:00:11 GMT
The reason why the tax authorities remain in compliance with Art. . Section 1, Paragraph 2 of the Corporate Income Tax Law has the right to challenge the correction under any of the following circumstances. It seems that due to the impact on the tax revenue of the state treasury, the statutory correction conditions are designed in this way, on the one hand, to protect the interests of the state treasury, on the other hand. It is to protect the interests of the national treasury. On the other hand, it prevents taxpayers from abusing their power.
Is every adjustment a transfer pricing adjustment? It turns out that the answer to this question also creates problems. The position expressed by the Under Secretary AWB Directory of State in his letter dated month of year in response to Inquiry No. may be helpful in resolving this issue. Based on the contents of the letter, an assessment is made as to whether a certain adjustment constitutes a transfer pricing adjustment within the meaning of Art. Whether the provisions of Article 1 of the Enterprise Income Tax Law and Article 1 of the Enterprise Income.
Tax Law are applicable shall be interpreted from the perspective of the conditions stipulated in the above provisions. A transfer pricing adjustment is therefore an adjustment made by an associated entity to a controlled transaction or a group of controlled transactions or the entire activities of an associated entity in order to adjust the transfer price realized during a specific period for tax purposes to a level consistent with the arm's length principle. Such adjustments should be made when factors outside the control of the parties.
Is every adjustment a transfer pricing adjustment? It turns out that the answer to this question also creates problems. The position expressed by the Under Secretary AWB Directory of State in his letter dated month of year in response to Inquiry No. may be helpful in resolving this issue. Based on the contents of the letter, an assessment is made as to whether a certain adjustment constitutes a transfer pricing adjustment within the meaning of Art. Whether the provisions of Article 1 of the Enterprise Income Tax Law and Article 1 of the Enterprise Income.
Tax Law are applicable shall be interpreted from the perspective of the conditions stipulated in the above provisions. A transfer pricing adjustment is therefore an adjustment made by an associated entity to a controlled transaction or a group of controlled transactions or the entire activities of an associated entity in order to adjust the transfer price realized during a specific period for tax purposes to a level consistent with the arm's length principle. Such adjustments should be made when factors outside the control of the parties.