Correlative Adjustments
21/04/1994
Query
Transfer pricing - whether to allow a correlative adjustment to compensate for the adjustment imposed by the IRS in the US
Decision
Agreed to allow a correlative adjustment in the company's liability to Irish tax to compensate for a retrospective adjustment imposed by the U.S. tax authority
Corporation Tax
Schedule 25, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:IR 10482/281/93