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...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Transfer-pricing adjustments for notional interest on delayed trade receivables may not be warranted where the taxpayer is completely debt-free and bears no interest cost on borrowings. The taxpayer's debt-free position requires verification from financial records before the adjustment can be removed. Verification is limited to that factual status; once established, the adjustment for interest on outstanding trade receivables is to be deleted. The matter is remitted for this limited verification, with consequential relief dependent on confirmation of the debt-free status.
Transfer-pricing adjustments for notional interest on delayed trade receivables may not be warranted where the taxpayer is completely debt-free and bears no interest cost on borrowings. The taxpayer's debt-free position requires verification from financial records before the adjustment can be removed. Verification is limited to that factual status; once established, the adjustment for interest on outstanding trade receivables is to be deleted. The matter is remitted for this limited verification, with consequential relief dependent on confirmation of the debt-free status.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4901 
