https://www.taxtmi.com/notifications?id=105735 The Committee recommends that low risk captive Development Centres satisfying cumulative FAR criteria be benchmarked by the Transactional Net Margin Method with an appropriate cost plus mark up, while Profit Split Method should be reserved for exceptional cost sharing or integrally linked intangible cases and used with extreme caution due to data and attribution difficulties. It urges updated CBDT guidance on FAR analysis, issuance of circulars to ensure uniform TP administration, and a set of sectoral clarifications: giving effect to deeming of "on site" exports, recognising DTM when connected to software development, privileging SoW over MSA for scope, treating R&D as eligible under export notifications, and preserving tax holidays on slump sales and SEZ relocations subject to fact based tests. en-us Fri, 14 Sep 2012 00:00:00 +0530 Tue, 02 Jul 2013 11:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/notifications?id=105735 The Committee recommends that low risk captive Development Centres satisfying cumulative FAR criteria be benchmarked by the Transactional Net Margin Method with an appropriate cost plus mark up, while Profit Split Method should be reserved for exceptional cost sharing or integrally linked intangible cases and used with extreme caution due to data and attribution difficulties. It urges updated CBDT guidance on FAR analysis, issuance of circulars to ensure uniform TP administration, and a set of sectoral clarifications: giving effect to deeming of "on site" exports, recognising DTM when connected to software development, privileging SoW over MSA for scope, treating R&D as eligible under export notifications, and preserving tax holidays on slump sales and SEZ relocations subject to fact based tests. Notifications Income Tax Fri, 14 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/notifications?id=105735