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Mr. Bishnu P. Nepal, IRD, Nepal

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Transfer Pricing (Sec 33)<br />

In any arrangement between persons who are associates, the<br />

department may, by notice in writing, distribute, apportion, or<br />

allocate amounts to be included or deducted in calculating<br />

income between the persons as is necessary to reflect the<br />

taxable income or tax payable that would have arisen for them<br />

if the arrangement had been conduction at arm’s length.

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