Articles
2 articles available
2 articles available
Corresponding adjustments and the MAP process When the price charged for goods or services sold between related parties is not in accordance with the arm’s length principle, Article 9(1) of the OECD…
The Existing Framework: Nexus and Profit Attribution Rules Under the current Double Taxation Avoidance Agreement (DTAA) framework, business profits are in principle taxable in the State of residence…