https://www.taxtmi.com/caselaws?id=762840 A corporate guarantee furnished to an associated enterprise is treated as an international transaction requiring arm's length benchmarking under transfer pricing principles. Where bank guarantee comparables are not reliable because the underlying banking arrangement is overseas, settled tribunal and jurisdictional precedent supports a lower commission benchmark. On that basis, the corporate guarantee commission is commonly restricted to 0.5% as a reasonable arm's length rate. en-us Tue, 08 Oct 2024 00:00:00 +0530 Mon, 09 Dec 2024 08:44:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762840 A corporate guarantee furnished to an associated enterprise is treated as an international transaction requiring arm's length benchmarking under transfer pricing principles. Where bank guarantee comparables are not reliable because the underlying banking arrangement is overseas, settled tribunal and jurisdictional precedent supports a lower commission benchmark. On that basis, the corporate guarantee commission is commonly restricted to 0.5% as a reasonable arm's length rate. Case-Laws Income Tax Tue, 08 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762840