Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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Completed unsold units held as a builder-developer's stock-in-trade may attract deemed annual-value taxation once occupancy or completion certificates have been issued. Notional rental income should be calculated using municipal rateable value, rather than an ad hoc percentage of the units' cost or investment. A unit for which purchaser advances have been received may be treated as sold and excluded from deemed rent where final possession has not been delivered, subject to verification of the claim and supporting material. The discussion notes remand for verification of the advance claim and recomputation of annual letting value on the municipal rateable-value basis.
Completed unsold units held as a builder-developer's stock-in-trade may attract deemed annual-value taxation once occupancy or completion certificates have been issued. Notional rental income should be calculated using municipal rateable value, rather than an ad hoc percentage of the units' cost or investment. A unit for which purchaser advances have been received may be treated as sold and excluded from deemed rent where final possession has not been delivered, subject to verification of the claim and supporting material. The discussion notes remand for verification of the advance claim and recomputation of annual letting value on the municipal rateable-value basis.
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