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Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allowed.
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Cost-to-cost recovery of salary and travel expenses for employees temporarily seconded to associated enterprises constitutes expense reimbursement rather than consideration for margin-bearing services where recovered exactly at cost. Accordingly, the transfer-pricing mark-up adjustment was deleted, supported by consistent treatment in other years and a bilateral Advance Pricing Agreement allowing recovery at cost. Amalgamation expenditure incurred after approval is amortised over five years beginning in the assessment year relevant to the year of expenditure, not the appointed amalgamation date. The fifth annual deduction was allowed because the claim had been accepted for the prior four years without changed facts.
Cost-to-cost recovery of salary and travel expenses for employees temporarily seconded to associated enterprises constitutes expense reimbursement rather than consideration for margin-bearing services where recovered exactly at cost. Accordingly, the transfer-pricing mark-up adjustment was deleted, supported by consistent treatment in other years and a bilateral Advance Pricing Agreement allowing recovery at cost. Amalgamation expenditure incurred after approval is amortised over five years beginning in the assessment year relevant to the year of expenditure, not the appointed amalgamation date. The fifth annual deduction was allowed because the claim had been accepted for the prior four years without changed facts.
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