Checkpoint Technologies Kenya Limited vs. Commissioner of Domestic Taxes (Tax Appeal 1181 of 2022)
Because Transfer pricing is not an exact science, precision can be challenging due to the varied methodologies. Sometimes, different methods yield a range of figures, all equally reliable. Article 3:62 of the OECD Transfer Pricing Guidelines for Multinational Enterprises acknowledges this and suggests that within such a range, any point can ...
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