Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Transfer pricing dispute over benchmarking of a guarantee commission: the article explains that the tax authority applied an ad hoc upward adjustment using a CUP-based market rate, but a tribunal relied on earlier coordinate-bench analysis that the combined guarantee fee approximated 0.69% and the assessee's allocated share (about 57%) reflected limited functions, absence of independent risk-bearing, and a back-to-back counter guarantee; applying that reasoning the tribunal found the TPO/DRP ad hoc rate untenable and deleted the upward transfer pricing adjustment to the guarantee commission for the year under review.
Transfer pricing dispute over benchmarking of a guarantee commission: the article explains that the tax authority applied an ad hoc upward adjustment using a CUP-based market rate, but a tribunal relied on earlier coordinate-bench analysis that the combined guarantee fee approximated 0.69% and the assessee's allocated share (about 57%) reflected limited functions, absence of independent risk-bearing, and a back-to-back counter guarantee; applying that reasoning the tribunal found the TPO/DRP ad hoc rate untenable and deleted the upward transfer pricing adjustment to the guarantee commission for the year under review.
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