Page 60 - Strategic Tax Planning for Global Commerce & Investment
P. 60
Tax Benefits for U.S. Exporters
2. If the agreed price between the parties falls
outside the range and as result the entity
pays lower taxes, the taxing authorities
could adjust prices and thus, income.
3. The OECD principles, and most taxing au-
thorities, consider market price the median
of the range
DIAGRAM ARM’S-LENGTH RANGE
2. If the agreed 1. If the
price is agreed
outside the price is
range, the PRICE RANGE within the
taxing au- range, the
thorities agreed
could adjust price is
considered
prices
the market
price
Prices resulting from
application of best method
52
