The notion of a special relationship:
In practice often occurs a business entity transacting with other business entities, while both are still in the same business group. In such case, do not close the possibility of related party transactions that are not reasonable. Therefore,
Article 18 of the Income Tax Act has limits on the special relationship, the special relationship is considered to exist if:
Taxpayers have equity participation, directly or indirectly, at least 25% in the other taxpayer, the relationship between the taxpayer at least 25% participation in two or more taxpayer as well as the relationship between the taxpayer two or more of the latter.
Tidak ada komentar :
Posting Komentar