Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Direct Port Delivery container clearance remains subject to a normal 48-hour limit from landing at the port terminal. Sundays and holidays observed by the Port and Customs are excluded when calculating that period, while Saturdays remain included. Containers not cleared within the applicable period will be shifted by rail to the designated CFS within 72 hours of landing. Where Customs clearance is not obtained within 72 hours, the containers will be treated as ordinary, non-DPD containers. All other DPD and Direct Port Entry procedures remain unchanged, with immediate effect.
Direct Port Delivery container clearance remains subject to a normal 48-hour limit from landing at the port terminal. Sundays and holidays observed by the Port and Customs are excluded when calculating that period, while Saturdays remain included. Containers not cleared within the applicable period will be shifted by rail to the designated CFS within 72 hours of landing. Where Customs clearance is not obtained within 72 hours, the containers will be treated as ordinary, non-DPD containers. All other DPD and Direct Port Entry procedures remain unchanged, with immediate effect.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
