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...
TDS u/s 195 - site testing charges - Royalty - the services which can independently or on stand alone basis, be provided, coupled with the fulfillment of the other requirement of Para 4(b) of the DTAA would only attract the ‘Fee for included services' - In the present case, the services, which are the subject matter of the dispute, do not fall under “Fee for incidental services”, hence, would not fall under Royalty and as such, not chargeable in India as per Clause 12 of DTAA - AT
TDS u/s 195 - site testing charges - Royalty - the services which can independently or on stand alone basis, be provided, coupled with the fulfillment of the other requirement of Para 4(b) of the DTAA would only attract the ‘Fee for included services' - In the present case, the services, which are the subject matter of the dispute, do not fall under “Fee for incidental services”, hence, would not fall under Royalty and as such, not chargeable in India as per Clause 12 of DTAA - AT
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