TPG2010 Chapter IX paragraph 9.185

Category: TPG2010 Part IV: Recognition of the actual transactions undertaken | Tag: , ,
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In both circumstances, Article 9 would allow an adjustment of conditions to reflect those which the parties would have attained had the transaction been structured in accordance with the economic and commercial reality of parties dealing at arm’s length (see paragraph 1.66). In doing so, tax administrations would have to determine what is the underlying reality behind a contractual arrangement in applying the arm’s length principle (see paragraph 1.67).






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