§ 1.482-1T(ii)
Posted on |
By Internal Revenue Service
Category: US IRC Section 482 on Transfer Pricing, § 1.482-1T Allocation of income and deductions among taxpayers (temporary). | Tag: Actual transaction, Aggregated transactions, Aggregation, Entire arrangement, Form or character of the transaction
« Prev |
Next » Related Guidelines
- TPG2022 Chapter I paragraph 1.141Every effort should be made to determine pricing for the actual transaction as accurately delineated under the arm’s length principle. The various tools and methods available to tax administrations and taxpayers to do so are set out in the following chapters of these Guidelines. A tax administration should not disregard...
- TPG2022 Chapter X paragraph 10.209In the process of accurately delineating the actual transaction involving a captive insurance, the economically relevant risks associated with issuing insurance policies, i.e. underwriting, must be identified with specificity. Part IV of the Report on the Attribution of Profits to Permanent Establishments provides a description of those risks that include,...
