Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Service tax on corporate guarantees arises only where consideration is received for rendering a taxable service. Corporate guarantees extended to associated enterprises without commission, fee or other consideration do not create taxable value merely because a notional amount can be computed using prevailing bank-guarantee rates. A precedent involving a corporate guarantee issued for paid consideration does not apply where the guarantee was provided without consideration. The demand for service tax on such guarantees was therefore dropped, and the Revenue's appeal was dismissed.
Service tax on corporate guarantees arises only where consideration is received for rendering a taxable service. Corporate guarantees extended to associated enterprises without commission, fee or other consideration do not create taxable value merely because a notional amount can be computed using prevailing bank-guarantee rates. A precedent involving a corporate guarantee issued for paid consideration does not apply where the guarantee was provided without consideration. The demand for service tax on such guarantees was therefore dropped, and the Revenue's appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
