Post by account_disabled on Mar 14, 2024 9:18:32 GMT 1
Were made in accordance with Article 1. festival and art. Section Corporate Income Tax Law Article. However, these regulations do not specify whether the tax base can be increased simply by increasing income or reducing deductible costs plus adjustments or whether the tax base can be reduced thereby reducing the tax base. The tax burden amount is reduced by adjustment. The interpretations of the tax authorities and the jurisprudence of the Administrative Court do not provide a clear answer. This resulted in a court judgment challenging the taxpayer's liability for year-end adjustments.
Holding that profit equalization under the legal status effective in the year was essentially an adjustment to profitability on the basis of the transfer pricing policy already adopted and did not AWB Directory comply with the provisions of Article condition. Section Corporate Income Tax Law Article 2 Particularly conditions related to income. The nature of the profitability adjustment precludes it being a charge for services provided by the supplier to the distributor.
The business plan outlined does not fall within the concept of transaction price within the meaning of Art. The phrasing of point 1 is applicable and therefore the business assessed cannot refer to the rules arising from article 1. Article 1 of the Corporate Income Tax Law. Supreme Administrative Court Year Month Day Judgment Reference Number . The nature of the profitability adjustment precludes it being a charge from the supplier for services provided to the distributor. The business plan outlined does not fall within the concept of transaction price within the meaning of Art. The phrasing of point 1 is applicable and therefore the business assessed cannot refer to the rules arising from article 1. Article 1 of the Corporate Income Tax Law.
Holding that profit equalization under the legal status effective in the year was essentially an adjustment to profitability on the basis of the transfer pricing policy already adopted and did not AWB Directory comply with the provisions of Article condition. Section Corporate Income Tax Law Article 2 Particularly conditions related to income. The nature of the profitability adjustment precludes it being a charge for services provided by the supplier to the distributor.
The business plan outlined does not fall within the concept of transaction price within the meaning of Art. The phrasing of point 1 is applicable and therefore the business assessed cannot refer to the rules arising from article 1. Article 1 of the Corporate Income Tax Law. Supreme Administrative Court Year Month Day Judgment Reference Number . The nature of the profitability adjustment precludes it being a charge from the supplier for services provided to the distributor. The business plan outlined does not fall within the concept of transaction price within the meaning of Art. The phrasing of point 1 is applicable and therefore the business assessed cannot refer to the rules arising from article 1. Article 1 of the Corporate Income Tax Law.