ASSOCIATION OF ENTERPRISES AS A BASIS OF THE CONTROLLED TRANSACTIONS
Journal Title: Науковий вісник Ужгородського національного університету. Серія: Право - Year 2018, Vol 49, Issue 2
Abstract
The article is devoted to the study of the criteria compliance for establishing the аssociation of enterprises under the national tax law with Article 9 of the OECD Model Convention, in particular, with regard to the recognition of enterprises associated on the basis of the relations of actual control. The authors prove that the criterion of establishing the association of enterprises for the purposes of transfer pricing on the basis of the relations of actual control is superfluous for the tax
Authors and Affiliations
С. Т. Кадькаленко, Т. С. Дуда
Keywords
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