INTM440040 - Transfer pricing: Types of transactions: land and buildings
Transactions involving land and buildings
The transfer pricing legislation at TIOPA10/Part 4 applies to transactions involving land and buildings. These sales, when taking place between connected persons, and where assessable as trading income, are subject to the arm바카라 사이트™s length principle. Profits that are chargeable as capital gains are not subject to TIOPA10/Part 4; instead the capital gains tax code requires the market value to be substituted for the sale price, where the sale is between connected persons.
Transactions that are subject to TIOPA10/Part 4 also include rent, premiums and services provided under letting agreements.