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...
Page of 4912
Press 'Enter' after typing page number.
221 to 240 of 98239 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Transfer-pricing adjustment on raw-material purchases routed through a pass-through associated enterprise is not warranted where the unrelated foreign supplier directly supplies the goods and credit notes reduce the effective price to that supplier's price. An additional invoiced component used solely for customs-duty valuation does not justify an arm's length price adjustment in those circumstances. Compliance with the direction concerning operating revenue results in no further adjustment. The transfer-pricing adjustment on these purchases was deleted and the appeal allowed.
Transfer-pricing adjustment on raw-material purchases routed through a pass-through associated enterprise is not warranted where the unrelated foreign supplier directly supplies the goods and credit notes reduce the effective price to that supplier's price. An additional invoiced component used solely for customs-duty valuation does not justify an arm's length price adjustment in those circumstances. Compliance with the direction concerning operating revenue results in no further adjustment. The transfer-pricing adjustment on these purchases was deleted and the appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4912 
