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IFA: Secondary Adjustments and Related Aspects of Transfer Pricing Corrections - Secondary Adjustments and Related Aspects of Transfer Pricing Corrections (Paperback)
Loot Price: R3,085
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IFA: Secondary Adjustments and Related Aspects of Transfer Pricing Corrections - Secondary Adjustments and Related Aspects of Transfer Pricing Corrections (Paperback)
Series: IFA Congress Series Set
Expected to ship within 10 - 15 working days
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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.
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