ERP System Cost-Sharing Requires Markup Under Transfer Pricing Rules for Assessee Company Services.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TPA - this is not a pure reimbursement of cost but cost sharing exercise in implementing ERP systems in the group - It certainly involves services by assessee company - mark up is warranted under the TP provisions. - AT....