Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Credit rating and annual surveillance receipts were held not taxable as fees for technical services under the India-Singapore DTAA because the determinative test was whether technical know-how, skill, technology or process had been made available to the client. The Tribunal found that clients received only the rating output, not the underlying expertise or technology used to produce it, and no know-how was transferred. The addition was therefore deleted.
Credit rating and annual surveillance receipts were held not taxable as fees for technical services under the India-Singapore DTAA because the determinative test was whether technical know-how, skill, technology or process had been made available to the client. The Tribunal found that clients received only the rating output, not the underlying expertise or technology used to produce it, and no know-how was transferred. The addition was therefore deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
