Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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TP adjustment - TPO accepted ALP based on TNMM but sought separate benchmarking of notional interest on the outstanding receivables - if the impact of extended credit period on working capital was factored in the pricing/profitability, then any credit period allowed to AE gets subsumed in TNMM and there is no tax leakage or evasive tactics adopted by the taxpayer while transacting with the AE, and there is no need for a separate benchmarking
TP adjustment - TPO accepted ALP based on TNMM but sought separate benchmarking of notional interest on the outstanding receivables - if the impact of extended credit period on working capital was factored in the pricing/profitability, then any credit period allowed to AE gets subsumed in TNMM and there is no tax leakage or evasive tactics adopted by the taxpayer while transacting with the AE, and there is no need for a separate benchmarking
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