Scrutiny of foreign royalty and technical service expense claims - enhanced verification and commissioner review required where excessive. Expense claims by foreign collaborators for royalties, technical service fees and know how must be subject to in depth scrutiny; assessing officers should consider alternative computation methods where appropriate. If claimed expenses exceed one third of gross receipts from royalties or technical service fees, the Commissioner of Income tax must review the case and advise assessing officers. Assessment recordkeeping for foreign companies should be improved, with remedial measures implemented and attention from newly created IAC ranges.
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.
Scrutiny of foreign royalty and technical service expense claims - enhanced verification and commissioner review required where excessive.
Expense claims by foreign collaborators for royalties, technical service fees and know how must be subject to in depth scrutiny; assessing officers should consider alternative computation methods where appropriate. If claimed expenses exceed one third of gross receipts from royalties or technical service fees, the Commissioner of Income tax must review the case and advise assessing officers. Assessment recordkeeping for foreign companies should be improved, with remedial measures implemented and attention from newly created IAC ranges.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
