Ingersoll-Rand Spain’s Low-Value Loan Bound by Transfer Pricing
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Ingersoll-Rand Spain’s Low-Value Loan Bound by Transfer Pricing
A Spanish court has ruled that a €250,000 minimum threshold for documenting low-value related-party transactions did not absolve Ingersoll-Rand's Spanish subsidiary from performing and recording an arm's-length test for an intercompany loan while also upholding the tax authorities' disallowance of the loss from the sale of Hussmann Koxka to a third party.
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