Employee stock-option discount qualifies as revenue expenditure, while royalty and service comparables require reliable functional and transactional benchmarking.

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....Employee stock-option discount is revenue expenditure where the liability accrues during the vesting period, notwithstanding the absence of cash outflow. Royalty benchmarking requires satisfaction of both associated-enterprise conditions and prefers reliable internal comparable uncontrolled price transactions, supported by examination of contractual, functional and consistency factors. Trading, IT support and digital marketing comparables must match the tested party's functions; entities with materially different activities, significant intangibles, unavailable segmental data or exceptional circumstances are unsuitable. The other method may use gross margin as a profit level indicator where purchase-to-sale price comparison is justified, capacity-utilisation differences affect direct-cost recovery, and TNMM adjustment data is unavailable.....