NYSE |$USD |Post-Market:$139.55+0.03 (+0.02%)6:17 PM AllAnalysisCommentsNewsTranscriptsSEC FilingsPress ReleasesRelated Analysis 1D 5D 1M 6M YTD 1Y 5Y 10Y MAX Basic Advanced Chart Combination chart with 2 data series. View as data table, Chart ...
The STAI decision confirms some important principles in transfer pricing disputes: In applying the “arm’s length test” for related party debt, the hypothetical construct should depart as little as possible from the actual loan and circumstances of the parties. Taxpayers cannot rely on ...
Net Debt4.77B5.02B More financial data* Estimated data Company Profile AtoS SE is one of the world leaders in IT services. The group's activity is organized around three sectors: - outsourcing services and consulting services; - system integration; - supply of transaction services: electronic pay...
a debt interest is issued to a connected entity, and the return paid to the connected entity is used to fund an equity-like return on investment held by a third person (the “ultimate recipient”). The effect of section 974-80 is to re-characterise the debt ...