https://www.taxtmi.com/news?id=11326 The Committee recommends that Indian captive Development Centres that cumulatively satisfy factual parameters of a contract R&D service provider with insignificant risk should be benchmarked using the Transactional Net Margin Method (TNMM) with an appropriate cost plus markup, while application of the Profit Split Method (PSM) is often impracticable due to lack of reliable global profit allocation data and should be applied only with extreme care. The Committee also advises issuing updated FAR guidance and circulars and clarifies that on site development deemed as export, SoWs govern scope over MSAs, DTM is eligible when connected to software development, R&D services should be notified as eligible for export deductions, slump sale transfers preserve tax holidays, separate books are not mandatory, and parity must be maintained in turnover computations. en-us Tue, 02 Jul 2013 09:59:42 +0530 Tue, 02 Jul 2013 10:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/news?id=11326 The Committee recommends that Indian captive Development Centres that cumulatively satisfy factual parameters of a contract R&D service provider with insignificant risk should be benchmarked using the Transactional Net Margin Method (TNMM) with an appropriate cost plus markup, while application of the Profit Split Method (PSM) is often impracticable due to lack of reliable global profit allocation data and should be applied only with extreme care. The Committee also advises issuing updated FAR guidance and circulars and clarifies that on site development deemed as export, SoWs govern scope over MSAs, DTM is eligible when connected to software development, R&D services should be notified as eligible for export deductions, slump sale transfers preserve tax holidays, separate books are not mandatory, and parity must be maintained in turnover computations. News - Tue, 02 Jul 2013 09:59:42 +0530 https://www.taxtmi.com/news?id=11326