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The international standard that OECD member countries have agreed
should be used for determining transfer prices for tax purposes. It is set forth
in Article 9 of the OECD Model Tax Convention as follows: where
“conditions are made or imposed between the two enterprises in their
commercial or financial relations which differ from those which would be
made between independent enterprises, then any profits which would, but
for those conditions, have accrued to one of the enterprises, but, by reason of
those conditions, have not so accrued, may be included in the profits of that
enterprise and taxed accordingly”.
4episodes
Episodes
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Episode 4
Jan 4, 201200:02:19Tap to summarizeThis is only a test for movie functions
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Episode 3
Jan 3, 201200:00:30Tap to summarizeAdvance pricing arrangement (“APA”) An arrangement that determines, in advance of controlled transactions, an appropriate set of criteria
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Episode 2
Jan 3, 201200:02:49Tap to summarizeThe international standard that OECD member countries have agreed should be used for determining transfer prices for tax purposes. It is set forth in Article 9 of the OECD Model Tax Convention as follows: where “conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly”.
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Jan 3, 201200:03:20Tap to summarizeThis is my 1st podcast to test
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