Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
TP adjustment - comparable selection - Rule 10B(4)- the data to be used in analysing the comparability of an uncontrolled transaction shall be the data relating to the financial year - proviso to this rule further provides that data relating to a period not being more than two years prior to [the current year] may also be considered if such data have an influence on the determination of TP in relation to the transactions being compared
TP adjustment - comparable selection - Rule 10B(4)- the data to be used in analysing the comparability of an uncontrolled transaction shall be the data relating to the financial year - proviso to this rule further provides that data relating to a period not being more than two years prior to [the current year] may also be considered if such data have an influence on the determination of TP in relation to the transactions being compared
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
