Thursday, March 20, 2008

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L57 LPF - Motivation corrections

administration address the taxpayer a proposed correction to be justified so as to enable him to comment or make known its acceptance [See also article L. 54 B ].


In case of application of Article L. 47 A , administration says the taxpayer the type of treatment used. When
to adjust the price or valuation of a business or a customer, pursuant to Article L. 17 , the administration is based on comparison with the disposal of other assets, the obligation to state reasons is actually completed by the indication:
1 dates mutations considered;
2 ° address funding or places of professions;
3 of the nature of the activities;
4 and the transfer price, sales or profits, whether this information are subject to compulsory disclosure, or otherwise, averages of these figures on the companies for which are provided to the matters described in paragraphs 1, 2 and 3.
When the administration rejects the comments of the taxpayer's response must also be motivated.

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