Business Dependence Establishes Associated Enterprise Status; Domestic Tested Party and Fresh Regulatory Affairs Benchmarking Required

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....Business dependence on regulatory affairs and compliance processes established an associated-enterprise relationship, which was sustained because the relationship had also been accepted in transfer-pricing documentation. Foreign associated-enterprise selection as the tested party was rejected where reliable foreign comparable data was not readily accessible and geographical and economic conditions differed; the assessee was retained as the tested party. Domain-specific regulatory affairs services were not treated as KPO services merely by reference to the Rule 10TA definition, and comparables from diverse R&D, engineering, IT, advertising and gaming activities were unsuitable. Fresh benchmarking and comparable selection were directed in line with the assessee's FAR profile after a hearing opportunity.....