https://www.taxtmi.com/article/detailed?id=5333 Safe harbour rules permit tax authorities to accept transfer prices declared by enumerated categories of assessees for specified international transactions if prescribed conditions are met. The framework defines eligible assessees and transactions, sets objective acceptance criteria (operating margins, interest spreads, guarantee fees), excludes dealings with notified or no/low-tax jurisdictions, and prescribes an opt-in procedure via Form 3CEFA with verification, referral to a Transfer Pricing Officer, and administrative review mechanisms. Identification of 'insignificant risk' relies on allocation of functions, funding, supervision, risk assumption, and intangible ownership. en-us Thu, 24 Oct 2013 09:32:37 +0530 Thu, 24 Oct 2013 09:32:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=5333 Safe harbour rules permit tax authorities to accept transfer prices declared by enumerated categories of assessees for specified international transactions if prescribed conditions are met. The framework defines eligible assessees and transactions, sets objective acceptance criteria (operating margins, interest spreads, guarantee fees), excludes dealings with notified or no/low-tax jurisdictions, and prescribes an opt-in procedure via Form 3CEFA with verification, referral to a Transfer Pricing Officer, and administrative review mechanisms. Identification of 'insignificant risk' relies on allocation of functions, funding, supervision, risk assumption, and intangible ownership. Articles Income Tax Thu, 24 Oct 2013 09:32:37 +0530 https://www.taxtmi.com/article/detailed?id=5333