The rules on transfer pricing (TP) are historically limited to international transactions only. Moreover, with effect from 1 April 2013, the scope of the transfer pricing has been expanded to different domestic transactions and is therefore active from the assessment year (A.Y) 2013-14. What d...
More complex for FP FIN 48 states that “each tax position must be evaluated without consideration of the possibility of offset or aggregation with other positions Unclear what happens to US transfer pricing position if you cannot reach more likely than not for FP,15, 19、Audit issues Multiple ...
consideration of the possibility of offset or aggregation with other positions Unclear what happens to US transfer pricing position if you cannot reach more likely than not for FP Audit issues – Multiple Adjustment Theories Measurement Similar analysis for US Sub and FP—what is the amount of U....