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International - The Object of Art. 9(1) of the OECD Model Convention: Commercial or Financial Relations

Country:
International
Author:
J. Wittendorff
Issue:
International Transfer Pricing Journal, 2010 (Volume 17), No 3
Published:
19 April 2010
This article examines two dimensions of the concept of a controlled transaction under Art. 9(1) of the OECD Model. The first part is an examination of the basic object qualification under Art. 9(1), treaty-based limits on the object qualification and the OECD position. Second, the delimitation of the controlled transaction for purpose of the arm’s length test under Art. 9(1) is examined.
 
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