Country of Origin Certificates and declared transaction value supported preferential customs exemption where authenticity and invoice prices remained ...
Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
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Appellants challenged TP adjustments on interest on receivables and management fees paid for intra-group services. Regarding receivables, HC relied on precedents holding that outstanding receivables beyond a period cannot be re-characterized as loans if impact is factored in working capital and pricing. On management fees, HC held TPO cannot doubt commercial expediency or disallow expenditure incurred for business purposes unless unrelated parties would not undertake it. TPO cannot restructure transactions unless economic substance differs from form or arrangements differ from those adopted by independent enterprises acting rationally. Expenditure on brand promotion cannot be disallowed if adequately compensated. Decision favored appellants.
Appellants challenged TP adjustments on interest on receivables and management fees paid for intra-group services. Regarding receivables, HC relied on precedents holding that outstanding receivables beyond a period cannot be re-characterized as loans if impact is factored in working capital and pricing. On management fees, HC held TPO cannot doubt commercial expediency or disallow expenditure incurred for business purposes unless unrelated parties would not undertake it. TPO cannot restructure transactions unless economic substance differs from form or arrangements differ from those adopted by independent enterprises acting rationally. Expenditure on brand promotion cannot be disallowed if adequately compensated. Decision favored appellants.
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