201s
Ftx*rNcs (No. 2)
(c)
(d)
No.9
the year(s) in rvhich the adjusted controlled transaction(s)
tcok place;
the amount of the requested conesponding adjustment and
the amounts of the adjustnrent rnade by the tax administration
of the other country;
(e)
evidence of the adjustment rnade by the tax administration of
the other country and the basis for the adjustment, including
details of comparability analysis relied upon and the transfer
pricing method applied;
(0
conlinnation that the related person party n'ill not, or is
unable to, pttrsue any further rec.ourse under the domestic
law of the other country that may result in the adjusturent
made by the tax administration of the other country being
reduced or reversed;
($
any other information that may be relevant for examining
the consistenc.y of the adjustment with the arrn's length
principle.
making
(5) The request rnust be made within the applicable time period for
request for the case to be resolved by way of mutual agreement
a
procedure under the applicable tax treaty.
Relevaftce of OECD Transfer Pricing Guidelines
13, The Organization for Economic Cooperation and Development
(OECD) "Transfer Pricing Guidelines for Multinational Enterprises and
Tax Administrationso' and the tIN Manual on the interpretation of transfcr
pricing are relevant sollrces of interpretation for this Schedule, There
may also be other relevant sources such as the United Nations Practical
Manual on Transfer Pricing for developing countries.".
PART
III
Srarw Durms
7
Condonation of underpayment of stamp duty on policies or certificates
of insurance, ete.
(1) The underpayment between the lst February, 2009, to the 30th July,
2015, of the stamp duty referred to in subsection (2) in the circumstances referred
to in subsection (3) is hereby condoned.
(2) The stamp duty in question is payable under item 5 ('?olicy of Insurance")
of the Schedule ("Stamp Duty on Instruments and other Matters") to Chapter II of
the Finance Act fChapter 23 :041.
(3) The underpayment resulted from the erroneous application by insurance
companies and insurance brokers (on the basis of mistaken advice communicated to
insurance companies and insurance brokers collectively) of stamp duty at the rate of
US$O01 instead of US$0,05 for every dollar worth of premiums payable on policies
or certificates of insurance or renewals tlrcreof or on other documents which are in
the form of guarantee, fidelity, security or surety bonds and u4rich are signed by an
insurance company or by any person transacting business on behalf of brokers or
underwriters at Lloyd's,
191
Select target paragraph3
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