Several commentators raised this concern after the initial Tax Court decision (6) and questioned whether Treasury can require a result that has been shown to be inconsistent with arm's-length
He favours an arm's-length
funding commission setting a four-year budget for each authority.
For example, under the new rules, certain services that are either specified in a revenue procedure or are low-margin services with an arm's-length
mark-up of 7 percent or less may qualify for pricing under the Service Cost Method (SCM) and may be charged out with no mark-up.
But despite making sweeping changes, he has stuck with the principle of arm's-length
funding for the arts.
Even though section 1041 nullified Davis on the recognition of gain requirement, the fact that transfers pursuant to a divorce are arm's-length
transactions still stands.
In both countries, large parts of the bureaucracy have been set up as agencies that work at arm's-length
from elected officials.
A written recruitment agreement was entered into pursuant to arm's-length
negotiations between the parties.
standard applies to items such as loans, rentals, services, sales, and the use of know-how, trademarks, patents and other intangibles.
Aura Gold's properties in the Inaja Greenstone Belt were acquired in nine separate arm's-length
agreements with the various landowners.
charge to each participant is the portion of the total costs of the services otherwise determined under the SCM properly allocated to the participant.
Updated TPMs: Six other articulated transfer pricing methods for determining the arm's-length
charge for intercompany services.
The OECD endorses strict application of the arm's-length
principle under these circumstances, and it recommends the valuation should be treated similarly to the way independent companies commonly value intangibles under similar conditions.