TPG2010 Chapter IX paragraph 9.164

Category: TPG2010 Part IV: Recognition of the actual transactions undertaken | Tag: , ,
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In the Article 9 context, an examination of the application of the arm’s length principle to controlled transactions should start from the transactions actually undertaken by the associated enterprises, and the terms of contracts play a major role (see paragraph 1.64). As acknowledged in paragraphs 1.47-1.51 and 1.64-1.69, however, such a review of the contractual terms is not sufficient.






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