§ 1.482-1T(i) Compensation independent of the form or character of controlled transaction –

Category: Transfer Pricing Guidelines, US IRC Section 482 on Transfer Pricing, § 1.482-1T Allocation of income and deductions among taxpayers (temporary). | Tag: , , , , ,
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  1. 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...
  2. Poland vs R. S.A., March 2023, Supreme Administrative Court, Cases No II FSK 2290/20In its application for an individual interpretation, R. S.A. stated that it distributes fast moving goods in Poland, Lithuania, Latvia and Estonia. It purchases these goods from the company E. based in H. and sells them to independent wholesale distributors and retailers. At...