Author: Steven C. Wrappe
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
Book Description
In this Part 3, we explore the KSA's historic approach to penalties and the motivation to develop transfer pricing-specific penalties. For sake of illustration, we will review the IRS reasons for enactment of transfer pricing-specific penalties, the substance of those penalties, and the IRS experience applying those penalties. The IRS experience could inform the KSA's consideration whether to enact transfer pricing penalties and, if so, how those penalties should be structured.