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...
Page of 4902
Press 'Enter' after typing page number.
1 to 20 of 98021 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Closely linked technical know-how fee and poultry feed premix purchase transactions may be aggregated for transfer-pricing purposes under Rules 10AD(d) and 10B. Where know-how fees are netted against premix purchase costs and the associated enterprise's invoice prices are accepted under the CUP method, the resulting reduction in net purchase cost supports arm's length treatment; the separate adjustment for know-how fees was deleted. Related-party performance incentives to directors cannot be disallowed merely because of the relationship. Disallowance requires material showing that expenditure is excessive or unreasonable against fair market value, legitimate business needs, or benefits derived. In the absence of findings or comparables, the incentive provision disallowance was deleted.
Closely linked technical know-how fee and poultry feed premix purchase transactions may be aggregated for transfer-pricing purposes under Rules 10AD(d) and 10B. Where know-how fees are netted against premix purchase costs and the associated enterprise's invoice prices are accepted under the CUP method, the resulting reduction in net purchase cost supports arm's length treatment; the separate adjustment for know-how fees was deleted. Related-party performance incentives to directors cannot be disallowed merely because of the relationship. Disallowance requires material showing that expenditure is excessive or unreasonable against fair market value, legitimate business needs, or benefits derived. In the absence of findings or comparables, the incentive provision disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
