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Under the Transactional Net Margin Method, selling commission paid to associated enterprises forms part of the operating cost of the software development services segment when it is closely linked to that segment. Where TNMM is accepted as the most appropriate method and the segment is accepted as arm's length, the commission cannot be isolated for separate benchmarking or assigned a nil arm's-length price after its inclusion in the segmental operating margin. Verification under an appellate direction resulted in deletion of the transfer-pricing adjustment, and the Revenue's challenge to the verification and consequential relief failed.
Under the Transactional Net Margin Method, selling commission paid to associated enterprises forms part of the operating cost of the software development services segment when it is closely linked to that segment. Where TNMM is accepted as the most appropriate method and the segment is accepted as arm's length, the commission cannot be isolated for separate benchmarking or assigned a nil arm's-length price after its inclusion in the segmental operating margin. Verification under an appellate direction resulted in deletion of the transfer-pricing adjustment, and the Revenue's challenge to the verification and consequential relief failed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
