International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Sales commission paid to an associated enterprise was supported by a written inter-company agreement and export-chain records, including purchase orders, supply instructions, invoices and shipping documents. The commission was linked to sales procured through the associated enterprise and became payable after third-party supply orders were received; the arm's length price was therefore not treated as nil. For delayed associated-enterprise receivables, the accepted TNMM operating margin and working-capital adjustment were considered to neutralise delayed realisation. As no differential credit benefit or real, determinable notional income was shown, a separate notional-interest adjustment was considered unwarranted. Both transfer-pricing adjustments were deleted.
Sales commission paid to an associated enterprise was supported by a written inter-company agreement and export-chain records, including purchase orders, supply instructions, invoices and shipping documents. The commission was linked to sales procured through the associated enterprise and became payable after third-party supply orders were received; the arm's length price was therefore not treated as nil. For delayed associated-enterprise receivables, the accepted TNMM operating margin and working-capital adjustment were considered to neutralise delayed realisation. As no differential credit benefit or real, determinable notional income was shown, a separate notional-interest adjustment was considered unwarranted. Both transfer-pricing adjustments were deleted.
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