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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Leasehold and project-operation rights held by a corporate debtor under BOT concession arrangements may form part of the liquidation estate and be sold as going-concern assets, even though land ownership remains with the counterparty. The sale transfers only the debtor's existing bundle of rights and does not confer superior rights on the purchaser. Pre-existing BOT rights, including the obligation to transfer the facility at the end of the concession term, remain protected and bind the purchaser. A liquidation sale may extinguish the debtor's liabilities after statutory distribution, but cannot transfer another party's equity interest. Completion of the sale process may be recorded subject to pending litigation where no challenge to the sale itself is made.
Leasehold and project-operation rights held by a corporate debtor under BOT concession arrangements may form part of the liquidation estate and be sold as going-concern assets, even though land ownership remains with the counterparty. The sale transfers only the debtor's existing bundle of rights and does not confer superior rights on the purchaser. Pre-existing BOT rights, including the obligation to transfer the facility at the end of the concession term, remain protected and bind the purchaser. A liquidation sale may extinguish the debtor's liabilities after statutory distribution, but cannot transfer another party's equity interest. Completion of the sale process may be recorded subject to pending litigation where no challenge to the sale itself is made.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4788
Join Channel
TaxTMI 
