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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The information / knowledge available to the assessee was made through a licence; consequently, it is covered under the definition of “royalty“ under the domestic law under section 19(1)(iv) and (vi) along with article 13(3) of the Double Taxation Avoidance Agreement with the U.K- AT
The information / knowledge available to the assessee was made through a licence; consequently, it is covered under the definition of “royalty“ under the domestic law under section 19(1)(iv) and (vi) along with article 13(3) of the Double Taxation Avoidance Agreement with the U.K- AT
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