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...
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TNMM functional comparability requires reliable evidence of the proposed comparable's activities during the relevant year. Entity-level margins of a diversified provider cannot support comparison with software development services where undated website descriptions and financial records do not establish segmental revenue or results; the comparable was excluded and the adjustment required recomputation, subject to the safe-harbour limit. Comparable margins must also be recomputed in line with DRP directions. For delayed foreign-currency receivables, arm's length interest cannot be fixed mechanically at a standard LIBOR spread; it requires analysis of the transaction, the associated enterprise's creditworthiness, and comparable uncontrolled rates. Domestic associated-enterprise receivables require verification before interest adjustment.
TNMM functional comparability requires reliable evidence of the proposed comparable's activities during the relevant year. Entity-level margins of a diversified provider cannot support comparison with software development services where undated website descriptions and financial records do not establish segmental revenue or results; the comparable was excluded and the adjustment required recomputation, subject to the safe-harbour limit. Comparable margins must also be recomputed in line with DRP directions. For delayed foreign-currency receivables, arm's length interest cannot be fixed mechanically at a standard LIBOR spread; it requires analysis of the transaction, the associated enterprise's creditworthiness, and comparable uncontrolled rates. Domestic associated-enterprise receivables require verification before interest adjustment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
