The following examples illustrate this paragraph (d)(3)(iii).
§ 1.482-1(d)(3)(iii)(C) Examples.
Category: (d) Comparability, Transfer Pricing Guidelines, US IRC Section 482 on Transfer Pricing, § 1.482-1 Allocation of income and deductions among taxpayers | Tag: Comparability, Comparability factors, Risk, Risk analysis - 6 step, Types of risks
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- Portugal vs “FURNITURE S.A.” No I, November 2021, CAAD, Case No 14/2021-TFurniture S.A is engaged in the production and sale of furniture and had established a US subsidiary to market and sell furniture overseas. The pricing of the controlled transactions with the US subsidiary had been based on a resale price method, which resulted...
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