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Transfer-pricing benchmarking of back-office support services...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise receivables.
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Transfer-pricing benchmarking of back-office support services requires comparables with similar functions and risk profiles; specialised engineering, knowledge-process, outsourced, geographically distinct businesses and entities affected by extraordinary events were excluded, while one comparable was retained, requiring recomputation of the adjustment. A low-risk captive service provider is entitled to a working-capital adjustment on furnishing supporting computations. Separate notional interest on associated-enterprise receivables cannot be charged where receivables are already reflected in working-capital adjustment and service pricing, as this duplicates the adjustment. Associated-enterprise cost allocations incurred without mark-up cannot be assigned a nil arm's length price absent evidence that services were not rendered or had nil cost. Unbilled revenue treatment for section 10A was remanded for recomputation.
Transfer-pricing benchmarking of back-office support services requires comparables with similar functions and risk profiles; specialised engineering, knowledge-process, outsourced, geographically distinct businesses and entities affected by extraordinary events were excluded, while one comparable was retained, requiring recomputation of the adjustment. A low-risk captive service provider is entitled to a working-capital adjustment on furnishing supporting computations. Separate notional interest on associated-enterprise receivables cannot be charged where receivables are already reflected in working-capital adjustment and service pricing, as this duplicates the adjustment. Associated-enterprise cost allocations incurred without mark-up cannot be assigned a nil arm's length price absent evidence that services were not rendered or had nil cost. Unbilled revenue treatment for section 10A was remanded for recomputation.
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