Article 8 - Application of Multiple Methods

A. It is not necessary to apply more than one method to determine the arm’s length remuneration for a given controlled Transaction.

B. Where a Taxable Person has used an Approved Transfer Pricing Methods to establish the remuneration of a Controlled Transaction and such method is consistent with the relevant provisions of the Bylaws to the satisfaction of the Authority, then the Authority’s examination of whether the remuneration of a Controlled Transaction is consistent with the Arm’s-Length principle shall be based on the Transfer Pricing method applied by the Taxable Person.
 

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