A taxpayer may seek on examination a reduction in a transfer pricing adjustment based on an unintentional over-reporting of taxable income. Tax administrations in their discretion may or may not grant this request. Tax administrations may also consider such requests in the context of mutual agreement procedures and corresponding adjustments (see Chapter IV).
TPG2017 Chapter III paragraph 3.17
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Comparability analysis, Internal set-offs, Tax reduction request, Unintentional over-reporting of taxable income
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