Tribunal Upholds Royalty Payments as Arm's Length, Validates Agreement Addendum Clarifying "Third Parties" Definition.

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....TP Adjustment - Adjustment in the transaction of payment of royalty - Royalty payments made by the subsidiary for using certain intangible properties and services. - The Tribunal acknowledged the addendum to the agreement as a legitimate clarification of the original intent, despite being executed retrospectively. It emphasized that the addendum did not introduce new terms but clarified the existing understanding regarding the scope of "Third Parties" and royalty payments. - The Tribunal rejected the Revenue's narrower interpretation of "Third Parties" that excluded transactions through Teleperformance USA. It affirmed that services rendered to Teleperformance USA's clients, facilitated by the subsidiary, qualified for royalty payments, ali.........