TPG2017 Chapter I paragraph 1.45

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Category: OECD Transfer Pricing Guidelines (2017) | Tag: , , , , , , , ,
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If the characteristics of the transaction that are economically relevant are inconsistent with the written contract between the associated enterprises, the actual transaction should generally be delineated for purposes of the transfer pricing analysis in accordance with the characteristics of the transaction reflected in the conduct of the parties.

Related Guidelines

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