This article codifies the internationally recognised arm’s length principle for all transactions between Related Parties. It mandates that such transactions must be priced as if they were conducted between independent entities under similar circumstances. To determine the arm’s length result, taxpayers must use one of five prescribed transfer pricing methods (CUP, Resale Price, Cost-Plus, TNMM, Profit Split) or another method if these are unsuitable. The Federal Tax Authority is empowered to adjust a Taxable Person’s income if a transaction does not meet this standard, and corresponding adjustments can be made for the counterparty.
Chapter 10 - Transactions with Related Parties and Connected Persons
Article 34 - Arm's Length Principle
[GTL Notes]
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