Document Fragment View

Matching Fragments

ITA 443/2013 & ITA 451/2013 Page 13
(v) the sum so arrived at is taken to be an arm's length price in relation to the supply of the property or provision of services by the enterprise;
(d) profit split method, which may be applicable mainly in international transactions or specified domestic transactions involving transfer of unique intangibles or in multiple international transactions or specified domestic transactions which are so interrelated that they cannot be evaluated separately for the purpose of determining the arm's length price of any one transaction, by which--