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Mr. Bishnu P. Nepal, IRD, Nepal

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Transfer Pricing (Sec 33)<br />

In making any adjustment under subsection the dept. may<br />

<br />

Re characterize the source and type of any income, loss, amount,<br />

or payment; or<br />

<br />

Allocate costs, including head office expenses, incurred by one<br />

person in conduction a business that benefit an associate or<br />

associates in conducting a business to the associates based on<br />

the comparative uncovers of the businesses.

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