The following examples illustrate the provisions of this paragraph (f)(2)(i). For purposes of the examples in this paragraph (E), P is a domestic corporation, and S1, S2, and S3 are foreign corporations that are wholly owned by P.
§ 1.482-1T(i)(E) Examples.
Category: Transfer Pricing Guidelines, US IRC Section 482 on Transfer Pricing, § 1.482-1T Allocation of income and deductions among taxpayers (temporary). | Tag: Actual transaction, Aggregated transactions, Aggregation, Best Method Rule, Entire arrangement, Form or character of the transaction, Labels, Most appropriate method (MAM), Most appropriate net profit indicator
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Next » Related Guidelines
- TPG2022 Chapter II paragraph 2.133Although most MNE groups are integrated to some extent, a particularly high degree of integration in certain business operations is an indicator for the consideration of the transactional profit split method. A high degree of integration means that the way in which one...
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Related Case Law
- Norway vs. Exxonmobil Production Norway Inc., January 2018, Lagsmanret no LB-2016-160306An assessment was issued by the Norwegian tax authorities for years 2009 2010 and 2011 concerning the interest on a loan between Exxonmobil Production Norway Inc. (EPNI) as the lender and Exxon Mobile Delaware Holdings Inc. (EMDHI) as the borrower. Both EPNI and...
- South Africa vs ABC (PTY) LTD, January 2021, Tax Court of Johannesburg, Case No IT 14305ABC Ltd is in the business of manufacturing, importing, and selling chemical products. It has a catalyst division that is focused on manufacturing and selling catalytic converters (catalysts). Catalysts are used in the abatement of harmful exhaust emissions from motor vehicles. To produce...
- Russia vs PJSC Uralkali, April 2019, Court of Appeal, Case No. А40-29025/2017PJSC Uralkali, produced and sold fertilizers (“potassium chloride”) through a related Swiss trader. Uralkali had informed the authorities about the controlled transaction and submitted the required TP documentation. To substantiate the pricing of the transaction they had applied the transactional net margin method...
- Ukrain vs Rivneazot, September 2019, Supreme Administrative Court, Case No 817/1737/17The Ukrainian group Rivneazot imports natural gas from – and exports mineral to – foreign related companies. The tax authority carried out an audit and concluded that the controlled prices of these transactions had not been determined in accordance with the arm’s length...
- Netherlands vs “Car B.V.”, 28 June 2002, Supreme Court, Case No 36446, ECLI:NL:HR:2002:AE4718In this case a Dutch subsidiary of a Japanese car group incurred losses related to import and sales of a specific car model. However in total the car importer remained profitable. The tax authorities claimed that the purchase price of the specific car...