Commentary

B4.122 Transfer pricing—transactions or a series of transactions

Business tax
Business tax | Commentary

B4.122 Transfer pricing—transactions or a series of transactions

Business tax | Commentary

B4.122 Transfer pricing—transactions or a series of transactions

The basic criteria for the application of the transfer pricing provisions requires there to be a provision made or imposed between any two persons by means of a transaction or series of transactions1.The legislation gives the term 'transaction' an extremely wide definition, to include arrangements, understandings and mutual practices whether or not they are intended to be legally enforceable2. An 'arrangement' is defined to mean a scheme or arrangement of any kind whether or not it is intended to be legally enforceable3.

A series of transactions is simply a number of transactions, not

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