Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Upper turnover filters in transfer-pricing comparable selection may be applied where differences in turnover, brand value, economies of scale, bargaining power and ownership of intangibles materially affect profitability and comparability. High-turnover software-development companies were treated as unsuitable comparables because their scale and functional profile differed from that of the tested party. The approach supports excluding enterprises exceeding the stated turnover threshold when scale-related factors distort an arm's-length comparison.
Upper turnover filters in transfer-pricing comparable selection may be applied where differences in turnover, brand value, economies of scale, bargaining power and ownership of intangibles materially affect profitability and comparability. High-turnover software-development companies were treated as unsuitable comparables because their scale and functional profile differed from that of the tested party. The approach supports excluding enterprises exceeding the stated turnover threshold when scale-related factors distort an arm's-length comparison.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
