https://www.taxtmi.com/circulars?id=52239 Guidance identifies contract R&D service providers with insignificant risk by reference to whether the foreign principal performs economically significant functions (including conceptualization, design and strategic direction), provides funds and economically significant assets and remunerates the Indian centre, actually controls and supervises core activities, and whether the Indian centre lacks ownership rights and does not assume economically significant realized risks; it also presumes a rebuttable absence of risk control where the principal is in a widely perceived low or no tax jurisdiction and directs revenue officers to decide based on conduct and totality of facts while selecting the most appropriate transfer pricing method. en-us Sat, 29 Jun 2013 00:00:00 +0530 Mon, 01 Jul 2013 10:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=52239 Guidance identifies contract R&D service providers with insignificant risk by reference to whether the foreign principal performs economically significant functions (including conceptualization, design and strategic direction), provides funds and economically significant assets and remunerates the Indian centre, actually controls and supervises core activities, and whether the Indian centre lacks ownership rights and does not assume economically significant realized risks; it also presumes a rebuttable absence of risk control where the principal is in a widely perceived low or no tax jurisdiction and directs revenue officers to decide based on conduct and totality of facts while selecting the most appropriate transfer pricing method. Circulars Income Tax Sat, 29 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/circulars?id=52239