Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Delayed trade receivables from associated enterprises are treated as a separate international transaction where realisation exceeds the normal credit period and provides an uncompensated financing benefit. Acceptance of the underlying IT/SDS service margin at arm's length, or inclusion of finance costs in operating costs, does not itself establish arm's-length compensation for extended credit. A debt-free service provider with no interest-bearing borrowings may not require a notional interest adjustment, subject to factual verification. For foreign-currency IT/SDS receivables, the article notes benchmarking at LIBOR plus 200 basis points after allowing a 60-day credit period.
Delayed trade receivables from associated enterprises are treated as a separate international transaction where realisation exceeds the normal credit period and provides an uncompensated financing benefit. Acceptance of the underlying IT/SDS service margin at arm's length, or inclusion of finance costs in operating costs, does not itself establish arm's-length compensation for extended credit. A debt-free service provider with no interest-bearing borrowings may not require a notional interest adjustment, subject to factual verification. For foreign-currency IT/SDS receivables, the article notes benchmarking at LIBOR plus 200 basis points after allowing a 60-day credit period.
Note: It is a system-generated summary and is for quick reference only.
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