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Tag Archives: transfer pricing in a cross-border context

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ANALYSIS: Arm’s length pricing between connected persons

Articles, DevelopBy Andre van der MerweMarch 1, 20142 Comments

Tax law generally applies to actual terms on which a transaction has been concluded as opposed to what the transaction would have been had it been entered into at arm’s length. Some exceptions exist where tax arbitrage can take place if the actual terms of a transaction are susceptible to manipulation. The most comprehensive of…

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