Transfer Pricing Adjustments Challenged: Transactions Misclassified as Trading Instead of Commission Activities, Ignoring Functional Profile Analysis.

Transfer pricing adjustments - determination of ALP - Functional profile not considered – transactions are akin to trading and cannot be considered activities of a commission agent or a broker - HC .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X