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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INR non-deliverable derivative contracts may be offered by Authorised Dealers to non-resident users only for hedging, replacing the previous unrestricted-purpose position. Authorised Dealers must maintain a Foreign Exchange Risk Reserve for INR foreign exchange derivative contracts undertaken to hedge currency risk on their own assets and liabilities where they purchase foreign currency against INR. The reserve must equal 20 per cent of each contract's INR-equivalent notional amount, be maintained as a daily cash deposit in India with RBI until contract termination, and applies to contracts undertaken after issuance of the directions.
INR non-deliverable derivative contracts may be offered by Authorised Dealers to non-resident users only for hedging, replacing the previous unrestricted-purpose position. Authorised Dealers must maintain a Foreign Exchange Risk Reserve for INR foreign exchange derivative contracts undertaken to hedge currency risk on their own assets and liabilities where they purchase foreign currency against INR. The reserve must equal 20 per cent of each contract's INR-equivalent notional amount, be maintained as a daily cash deposit in India with RBI until contract termination, and applies to contracts undertaken after issuance of the directions.
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