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...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
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Article 12(4) of the India-Singapore DTAA confines fees for technical services to managerial, technical or consultancy services that are ancillary and subsidiary to royalty, make available technical knowledge enabling independent application, or involve development and transfer of a technical plan or design. Management and business-support services do not qualify merely because they are commercially valuable, specialised or recurring. The treaty inquiry turns on contractual deliverables, actual work performed, material transferred, and whether the recipient acquires autonomous technical capability; continuing dependence on the provider may evidence no transfer. Where more beneficial, the treaty limitation prevails over the broader domestic FTS definition, subject to treaty-residence and prescribed-document requirements.
Article 12(4) of the India-Singapore DTAA confines fees for technical services to managerial, technical or consultancy services that are ancillary and subsidiary to royalty, make available technical knowledge enabling independent application, or involve development and transfer of a technical plan or design. Management and business-support services do not qualify merely because they are commercially valuable, specialised or recurring. The treaty inquiry turns on contractual deliverables, actual work performed, material transferred, and whether the recipient acquires autonomous technical capability; continuing dependence on the provider may evidence no transfer. Where more beneficial, the treaty limitation prevails over the broader domestic FTS definition, subject to treaty-residence and prescribed-document requirements.
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