Safe harbour definitions for international transactions set the scope of eligible services, costs, revenues, and transfer pricing concepts. Rule 86 defines the terms used for the safe harbour rules governing international transactions. It covers the meaning of accountant, several categories of services and products such as contract research and development services, data centre services, information technology enabled services, knowledge process outsourcing services, and software development services, as well as intra-group loan, low value-adding intra-group services, no tax or low tax country or territory, operating expense, operating revenue, operating profit margin, and relevant tax year. The definitions specify both inclusions and exclusions for safe harbour computation.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Safe harbour definitions for international transactions set the scope of eligible services, costs, revenues, and transfer pricing concepts.
Rule 86 defines the terms used for the safe harbour rules governing international transactions. It covers the meaning of accountant, several categories of services and products such as contract research and development services, data centre services, information technology enabled services, knowledge process outsourcing services, and software development services, as well as intra-group loan, low value-adding intra-group services, no tax or low tax country or territory, operating expense, operating revenue, operating profit margin, and relevant tax year. The definitions specify both inclusions and exclusions for safe harbour computation.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
AI OCR ✕
of 
TaxTMI 
TaxTMI 
