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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Interest on delayed customs refunds of excess duty following reassessment commences after three months from receipt of the refund application, rather than from the later reassessment or refund order. Where the importer pursued reassessment and refund but Revenue delayed action for several years, the delay is attributable to Revenue. Interest was therefore payable from 20.02.2019 until the refund date. The applicable rate was 12 per cent, not 6 per cent, because the refund was withheld through prolonged inaction. The balance interest was required to be paid within eight weeks.
Interest on delayed customs refunds of excess duty following reassessment commences after three months from receipt of the refund application, rather than from the later reassessment or refund order. Where the importer pursued reassessment and refund but Revenue delayed action for several years, the delay is attributable to Revenue. Interest was therefore payable from 20.02.2019 until the refund date. The applicable rate was 12 per cent, not 6 per cent, because the refund was withheld through prolonged inaction. The balance interest was required to be paid within eight weeks.
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