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Income Tax - Highlights / Catch Notes

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ALP adjustments - there is a school of thought that a domestic ...

Income Tax

November 24, 2016

ALP adjustments - there is a school of thought that a domestic arm’s length principle, which is what transfer pricing legislation represents, goes much beyond a tax treaty’s normal rule making scope since this arm’s length principle governs taxation of an enterprise in general and the tax treaties do not restrict domestic law in this respect - AT

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