Where the price of an international transaction in which either party to the transaction is a foreign related party is lower or higher than the arm’s length price, the tax authority may determine or rectify the tax base and tax amount of a resident (including a domestic corporation and a domestic place of business; hereafter the same shall apply in this Chapter) based on the arm’s length price: Provided, That where the same method of computing the arm’s length price among the methods prescribed in Article 5 applies to computation of the arm’s length price for at least two taxable years, and the tax base and tax amount for some of such taxable years are determined or rectified based on the arm’s length price so computed, the tax base and tax amount for the remaining taxable years shall also be determined or rectified based on the same arm’s length price
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