Tag: Consolidated group

§ 1.482-7(j)(2)(i) Consolidated group.

/ CCA/CSA, CCA/CSA - methods for pricing, Consolidated group, Cost Contribution Arrangement (CCA), Cost Sharing Arrangement (CSA), Special Rules, US IRC Section 482 on Transfer Pricing, § 1.482-7 Methods to determine taxable income in connection with a cost sharing arrangement
For purposes of this section, all members of the same consolidated group shall be treated as one taxpayer. For these purposes, the term consolidated group means all members of a group of controlled entities created or organized within a single country and subjected to an income tax by such country on the basis of their combined income ... Read more