Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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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