IT-468R "Management or Administration Fees Paid to Non-residents" (Archived) 29 December 1999

5. ...[T]he term "management or administration" generally includes the functions of planning, direction, control, co-ordination, systems or other...

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The portion of a management or administration fee paid to a non-resident affiliate that is in excess of a reasonable amount may be treated as a...

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RC is prepared to accept an allocation of the costs, direct and indirect, reasonably attributable to providing the relevant services to the...

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Where the treaty does not contain a specific article on management or administration fees, such fees paid to the non-resident will, to the extent...

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8. The Department considers that the term "a specific expense"...applies to a particular expense item or a portion thereof, a sum of several...

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