Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Under the mercantile system, contingent contractual consideration does not accrue merely because it is stated in an agreement; taxable income requires a vested, unconditional and enforceable right and a corresponding debt due. Where a contractual tranche depends on conditions, step-in rights and deductible costs, uncertainty over receipt and quantification prevents real income from accruing. Accounting Standard-9 requires reasonable certainty of ultimate collection, while later recovery proceedings may corroborate existing uncertainty. Under the percentage completion method, project expenditure carried in work-in-progress may be claimed when corresponding revenue is recognised, provided it relates to the project and is not deducted twice.
Under the mercantile system, contingent contractual consideration does not accrue merely because it is stated in an agreement; taxable income requires a vested, unconditional and enforceable right and a corresponding debt due. Where a contractual tranche depends on conditions, step-in rights and deductible costs, uncertainty over receipt and quantification prevents real income from accruing. Accounting Standard-9 requires reasonable certainty of ultimate collection, while later recovery proceedings may corroborate existing uncertainty. Under the percentage completion method, project expenditure carried in work-in-progress may be claimed when corresponding revenue is recognised, provided it relates to the project and is not deducted twice.
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