Transfer-pricing treatment of intra-group management and...

Transfer-pricing treatment of intra-group management and technical services requires evidence that services were rendered, availed and commensurate with the charge, including agreements, allocation methodology, invoices and correspondence. Commercial expediency remains the taxpayer's business judgment: the TPO cannot replace it or insist on immediate benefits, and an arm's length price should not be fixed at nil where evidence supports the services. For outstanding associated-enterprise receivables, interest is benchmarked at LIBOR plus 200 basis points after a 60-day credit period, requiring recomputation on that basis.