- 8 Marks
AT – April 2022 – L3 – Q2a – Anti-avoidance measures
Discuss four factors the Commissioner-General will consider in comparability analysis for transfer pricing arrangements.
Question
In response to some taxpayers’ behaviour, transfer pricing regulation has been passed to ensure that all arrangements are conducted at arm’s length. The Commissioner-General in his dealings with taxpayers must ensure that market price drives business transactions. The Commissioner-General reserves the right to allege abuse of transfer pricing if certain factors point to the fact that there is an arrangement not in accord with the dictate of market forces.
Required:
Explain FOUR (4) factors the Commissioner-General will rely on in his comparability analysis in Transfer Pricing arrangements.
Find Related Questions by Tags, levels, etc.
- Tags: Arm's Length Principle, Comparability Analysis, Transfer Pricing
- Level: Level 3
- Topic: Anti-avoidance measures
- Series: APR 2022
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