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Income Tax - Highlights / Catch Notes

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TP Adjustment - comparable selection - The issues included the ...

Income Tax

March 22, 2024

TP Adjustment - comparable selection - The issues included the rejection of the CUP method, selection of comparable companies, and rejection of a foreign Associated Enterprise as the tested party. The Tribunal upheld the transfer pricing adjustment but directed the exclusion of one comparable and the inclusion of another based on the arguments presented.

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