Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments cannot survive statutory omission.

Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments cannot survive statutory omission. https://www.taxtmi.com/highlights?id=102381 Corporate guarantees to subsidiaries are described as shareholder activities but, following retrospective inclusion within capital financing, remain international transactions requiring arm's length benchmarking; the guarantee commission was restricted to 0.5%. Omission without a saving clause of the specified domestic transaction category for related-party expenditure invalidated the related transfer-pricing reference and adjustment. Common head-office costs may be allocated at cost among eligible and non-eligible units because the head office is a cost centre, not an independent service provider. Interest-free advances to overseas associated enterprises require arm's length interest benchmarking despite own funds or commercial expediency. Recurring advertisement, brand-promotion and market-research expenditure was treated as revenue expenditure, not capital expenditure. en-us Wed, 05 Aug 2026 08:48:02 +0530 Wed, 05 Aug 2026 08:48:02 +0530 TaxTMI RSS Generator Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments cannot survive statutory omission. https://www.taxtmi.com/highlights?id=102381 Corporate guarantees to subsidiaries are described as shareholder activities but, following retrospective inclusion within capital financing, remain international transactions requiring arm's length benchmarking; the guarantee commission was restricted to 0.5%. Omission without a saving clause of the specified domestic transaction category for related-party expenditure invalidated the related transfer-pricing reference and adjustment. Common head-office costs may be allocated at cost among eligible and non-eligible units because the head office is a cost centre, not an independent service provider. Interest-free advances to overseas associated enterprises require arm's length interest benchmarking despite own funds or commercial expediency. Recurring advertisement, brand-promotion and market-research expenditure was treated as revenue expenditure, not capital expenditure. Highlights Income Tax Wed, 05 Aug 2026 08:48:02 +0530 https://www.taxtmi.com/highlights?id=102381