Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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...
Transfer-pricing treatment of corporate guarantees to wholly owned associated enterprises is discussed as requiring an arm's length commission of 0.5%, rather than a bank-guarantee rate of 1.90%. For outstanding foreign-currency receivables from associated enterprises, the relevant benchmark is the market rate for the transaction currency, identified as LIBOR plus 200 basis points rather than domestic lending or deposit rates. A normal interest-free credit period of 60 days is to be allowed before computing interest. The resulting adjustments are confined to the guarantee commission and recomputation of receivables interest on those parameters.
Transfer-pricing treatment of corporate guarantees to wholly owned associated enterprises is discussed as requiring an arm's length commission of 0.5%, rather than a bank-guarantee rate of 1.90%. For outstanding foreign-currency receivables from associated enterprises, the relevant benchmark is the market rate for the transaction currency, identified as LIBOR plus 200 basis points rather than domestic lending or deposit rates. A normal interest-free credit period of 60 days is to be allowed before computing interest. The resulting adjustments are confined to the guarantee commission and recomputation of receivables interest on those parameters.
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