Secondary adjustments and related aspects of transfer pricing corrections : proceedings of a seminar held in Toronto, Canada, in 1994 during the 48th Congress of the International Fiscal Association
著者
書誌事項
Secondary adjustments and related aspects of transfer pricing corrections : proceedings of a seminar held in Toronto, Canada, in 1994 during the 48th Congress of the International Fiscal Association
（IFA Congress seminar series, v. 19b）
Kluwer Law International, c1996
- : pbk
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内容説明・目次
内容説明
This seminar focused not only on the technical consideration of secondary aspects but also on the underlying philosophical question: namely, should secondary adjustments be employed at all and, if so, what are the appropriate limitations on their use? While a "corresponding adjustment" may be appropriate in order to avoid double taxation, other secondary adjustments, such as "conforming adjustments" and "reclassification of income" are more problematic. The panellists and audience were asked to consider the implications of secondary adjustments in the context of tax compliance, tax administration, and private contracts. Is it appropriate for the tax administrator to intervene in private transactions to the extent of "deeming" a capital contribution or "deeming" a dividend? Set-offs and corresponding adjustments, as well as about secondary adjustments, such as reclassification of income, are included here. Following the outline are examples and diagrams that explicate the principles explained in the outline, as well as papers prepared by individual panellists.
目次
- Secondary adjustments and related aspects of transfer pricing corrections. Summaries and examples
- S.D. Peterson, F.M. Horner, E. Hess. Note on Secondary Adjustments
- R. Himino. The Secondary Aspects of Transfer Pricing
- A.R. Lopez. How to Avoid Transfer Pricing Adjustments? H. Becker. Summary of Proceedings of the Seminar
- B. Bracewell-Milnes.
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