Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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TNMM comparability for marketing-support commission should primarily rest on functional, asset and risk analysis where reliable segmental data exists. A low-risk indenting-services segment without inventory or credit risk may be comparable despite the entity's wider trading activity or different products. LIBOR is the appropriate benchmark for foreign-currency loans to wholly owned subsidiaries; additional risk mark-up requires demonstrated differential risk, and contractual LIBOR-plus rates may be arm's length. Delayed associated-enterprise receivables remain separately examinable international transactions, but notional interest should not be charged where working-capital adjustment already captures the receivables effect and the tested party's adjusted margin exceeds comparable margins, subject to verification.
TNMM comparability for marketing-support commission should primarily rest on functional, asset and risk analysis where reliable segmental data exists. A low-risk indenting-services segment without inventory or credit risk may be comparable despite the entity's wider trading activity or different products. LIBOR is the appropriate benchmark for foreign-currency loans to wholly owned subsidiaries; additional risk mark-up requires demonstrated differential risk, and contractual LIBOR-plus rates may be arm's length. Delayed associated-enterprise receivables remain separately examinable international transactions, but notional interest should not be charged where working-capital adjustment already captures the receivables effect and the tested party's adjusted margin exceeds comparable margins, subject to verification.
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