The draft offer more detailed guidance on the principles of comparative analysis, including the application
of the methods of determining transfer prices are OECD acknowledged. However, the draft also emphasizes any applicable method also must not lead to the loss of tax revenue for the State budget, and this is a point to be considered inconsistent with the principle of trading independence. The draft may create some pressure on the taxpayer to prove that its trade links not only to comply with the principles of independence, but also deals not distract from Bank remittance State policy.
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