Transfer Pricing Officer jurisdiction is transaction-specific, excluding permanent establishment determinations and requiring independent assessment o...
Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Consistent treatment of depreciation in calculating the profit level indicator under the Transactional Net Margin Method is necessary for a valid arm's-length comparison. Including depreciation in an assessee's operating cost while excluding it from comparable companies' operating costs produces an anomalous comparison and can distort the assessed margin. Recomputing the assessee's margin without depreciation, consistently with the comparables, placed the international transactions with associated enterprises at arm's length. The resulting arm's-length price adjustment and related addition were deleted.
Consistent treatment of depreciation in calculating the profit level indicator under the Transactional Net Margin Method is necessary for a valid arm's-length comparison. Including depreciation in an assessee's operating cost while excluding it from comparable companies' operating costs produces an anomalous comparison and can distort the assessed margin. Recomputing the assessee's margin without depreciation, consistently with the comparables, placed the international transactions with associated enterprises at arm's length. The resulting arm's-length price adjustment and related addition were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
