Transfer Pricing Adjustment definition

Transfer Pricing Adjustment means an adjustment made by the competent authority of a Contracting State to the profits of an enterprise as a result of applying the domestic law concerning taxes referred to in Article 2 of that State regarding transfer pricing.

Transfer Pricing Adjustment means any proposed or actual allocation by a Tax Authority of any Tax Item between or among any member of the ParentCo Group and any member of the SpinCo Group with respect to any Tax Period ending prior to or including the Distribution Date.

Transfer Pricing Adjustment means the computation of profits or losses for Tax purposes in relation to any transaction or series of transactions on a basis which substitutes arm’s length terms for the actual terms agreed.

Examples of Transfer Pricing Adjustment in a sentence

• In the event that a member of the ParentCo Group, on the one hand, or a member of the SpinCo Group, on the other hand, suffers a Tax detriment as a result of a Transfer Pricing Adjustment, the Companies shall cooperate pursuant to this Article VII to seek any competent authority relief that may be available with respect to such Transfer Pricing Adjustment.

• In the event that a member of the Remainco Group, on the one hand, or a member of the Spinco Group, on the other hand, suffers a Tax detriment as a result of a Transfer Pricing Adjustment, the Companies shall cooperate pursuant to this Section 8 to seek any competent authority relief that may be available with respect to such Transfer Pricing Adjustment.

• For this reason, this report does not ① Article 28 Transfer Pricing Adjustment Methods for Purchases and Sales of Tangible Assets:...(IV) Other appropriate methods: If none of the first three methods are applicable, the tax authorities can choose other reasonable methods, such as “profit-comparison method”“profit-split method” and “net profit method”, among others.

• If pursuant to a Final Determination any Transfer Pricing Adjustment is made which results in (i) a Tax for which DuPont is liable hereunder and (ii) a Tax Benefit allowable to a member of the Chemours Group, Chemours shall make payment to DuPont, within thirty (30) days following such Final Determination, in an amount equal to the present value of such Tax Benefit (including any Tax Benefit made allowable as a result of the payment).

• In the event that a member of the DuPont Group, on the one hand, or a member of the Chemours Group, on the other hand, suffers a Tax detriment as a result of a Transfer Pricing Adjustment, the Companies shall cooperate pursuant to this Section 7 to seek any competent authority relief that may be available with respect to such Transfer Pricing Adjustment.

More Definitions of Transfer Pricing Adjustment

Transfer Pricing Adjustment means an adjustment made by the competent authority of a Party to the profits of an enterprise as a result of applying the domestic law concerning taxes referred to in Article 2 of that Party regarding transfer pricing.

Transfer Pricing Adjustment means any proposed or actual allocation by a Tax Authority of any Tax Item between or among any member of the Houston Group and any member of the Seattle Group with respect to any Pre-Distribution Period.

Transfer Pricing Adjustment means any proposed or actual allocation by a Tax Authority of any Tax Item between or among any member of the Pfizer Group and any member of the Zoetis Group with respect to any Tax Period ending prior to or including the final Distribution Date or the date of any Other Disposition, as the case may be.

Transfer Pricing Adjustment means any proposed or actual allocation by a Tax Authority of any Tax Item between or among any member of the Manitowoc ParentCo Group and any member of the SpinCo Group with respect to any Tax Period ending prior to or including the Distribution Date.

Transfer Pricing Adjustment means any proposed or actual allocation by a Tax Authority of any Tax Item between or among any member of the DuPont Group and any member of the Chemours Group with respect to any Tax Period ending prior to or including the Distribution Date.

Transfer Pricing Adjustment means any proposed or actual allocation, adjustment or imposition by a Tax Authority of any Tax Item (whether imputed or otherwise) between or among any member of the Grace Group in one taxing jurisdiction and any member of the GCP Group in a different taxing jurisdiction with respect to any intercompany transfer price in any period.

Transfer Pricing Adjustment means any proposed or actual allocation by a Tax Authority of any Tax Item between or among any member of the HP Group and any member of the Enterprise Group with respect to any Pre- Distribution Period.