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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Delayed trade receivables from an associated enterprise that remain unpaid beyond the agreed credit period are treated as a separate financing transaction and require independent arm's length benchmarking. Only the delay exceeding the actual arm's length credit period should attract interest, calculated in the receivable currency with a justified spread; LIBOR plus 200 basis points is prescribed for foreign-currency receivables. For ITES comparable selection, verification is required of the service-income and 25% related-party transaction filters. The turnover filter excludes companies with turnover above ten times or below one-tenth of the tested party's turnover.
Delayed trade receivables from an associated enterprise that remain unpaid beyond the agreed credit period are treated as a separate financing transaction and require independent arm's length benchmarking. Only the delay exceeding the actual arm's length credit period should attract interest, calculated in the receivable currency with a justified spread; LIBOR plus 200 basis points is prescribed for foreign-currency receivables. For ITES comparable selection, verification is required of the service-income and 25% related-party transaction filters. The turnover filter excludes companies with turnover above ten times or below one-tenth of the tested party's turnover.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
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