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Post by account_disabled on Oct 26, 2023 3:12:35 GMT -5
On the other hand, the taxpayer would be largely exempt from the documentation obligations in this regard and would not need to submit a comparative analysis for these transactions. Introducing additional options for determining market price Regulations have been introduced that allow the use of other transfer price calculation methods in addition to the five basic methods, including the valuation technique. That is most appropriate in a given situation. This will enable tax authorities to more efficiently verify that conditions between related entities comply with market conditions. When choosing the most moible number data appropriate method in a particular case particular consideration is given to the conditions established or imposed between the entities involved, the availability of information required for the correct application of the method and the specific criteria for its application. Applicable conditions for transfer pricing adjustments. The revised Act provides that taxpayers may adjust transfer prices by changing the income earned or the costs incurred to earn the income. Adjustments can be made if the following conditions are met: a controlled transaction is concluded in accordance with market conditions; there are significant changes in circumstances that affect the conditions of a controlled transaction; or adjustments are required to ensure that they comply with market conditions; the costs or gains actually incurred in the relevant tax year are obtained.
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