Links from Section 835D | ||
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Act | Linked to | Context |
Finance Act 2022 |
“transfer pricing guidelines” means the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations published by the OECD on 20 January 2022 supplemented by such additional guidance, published by the OECD on or after the date of passing of the Finance Act 2022, as may be designated by the Minister for Finance for the purposes of this Part by order made under subsection (3). |
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Taxes Consolidation Act, 1997 |
(a) the effect which is to be given to section 835C, and |
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Links to Section 835D (from within TaxSource Total) | ||
Act | Linked from | Context |
Taxes Consolidation Act, 1997 |
(b) For the purpose of determining the effect which would be given if double taxation relief arrangements referred to in paragraph (a)(ii) were to be applied, in accordance with the authorised OECD approach guidance, as required by paragraph (a)(ii), references to ‘Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations’ and ‘the Guidelines’ in the authorised OECD approach guidance shall be construed, as far as is practicable, as references to the transfer pricing guidelines (within the meaning of section 835D). |
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Taxes Consolidation Act, 1997 |
(ii) ‘transfer pricing method’, ‘tested party’, ‘selected comparable uncontrolled transactions (internal or external)’, ‘relevant financial indicators for independent enterprises’ and ‘comparable search methodology’ shall be construed in accordance with the transfer pricing guidelines (within the meaning of section 835D). |
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Taxes Consolidation Act, 1997 |
Where a relevant company is a company to which Part 35A applies, then section 835D shall apply, with any necessary modifications, to: |
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Taxes Consolidation Act, 1997 |
“group” (other than in the definition of “transfer pricing guidelines” in section 835D(1)) means a company which has one or more 75 per cent subsidiaries together with those subsidiaries; |
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Taxes Consolidation Act, 1997 |
(b) applying the transfer pricing method set out in the transfer pricing guidelines (as defined in section 835D) that is, in the circumstances, the most appropriate so as to determine the arm’s length amount of consideration for the identified arrangement. |