Kernrechtsfrage
Whether the arm's-length value of architecture services to related persons could be determined by estimation using SIA/KBOB standards and time-based calculations.
Extrahierter Entscheid
Yes. The authority could estimate the taxable consideration under the arm's-length standard; the SIA/KBOB-based method was suitable and the taxpayer failed to prove it was clearly wrong.
Extrahierte Begründung
For related-party transactions, the value must correspond to what independent parties would agree. If no directly comparable prices exist, the tax authority may estimate the amount using a plausible method reflecting the business reality. The taxpayer did not show that its alleged flat-fee practice or market conditions made the method unsuitable.