CategoriesTransfer Pricing

A Trading Entity Is Not a Service Provider: How to Defend the Resale Price Method Against a TNMM Adjustment in India

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CategoriesTransfer Pricing

Contract R&D or Routine Software Development: How the Functional Profile Decides the Transfer Pricing Method in India

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CategoriesTransfer Pricing

Defending the Residual Profit Split Method in India When the TPO Proposes TNMM for an Intangible-Owning Entity

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CategoriesTransfer Pricing

When Is the Berry Ratio the Right Profit Level Indicator for a Limited Risk Contract Manufacturer in India?

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CategoriesTax Advisory

Seconding Staff Between India and the UK: Employer, Permanent Establishment and Payroll Tax Are Different Questions

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CategoriesTax Advisory

Digital Platforms and India Tax Once the Equalisation Levy Is Gone: SEP, Treaty and PE Compared

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CategoriesTransfer Pricing

Decoding Intra-Group Services: Transfer Pricing, Documentation and Litigation in India

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Corporate Guarantee Fee: Transfer Pricing, TDS and GST
CategoriesTax Advisory

Parent Guarantee of an Indian Subsidiary: How Transfer Pricing, Withholding and GST Fit Together

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CategoriesTax Advisory

Shared Services from Singapore: Applying the ‘Make Available’ Test to Indian Withholding

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