TMI BlogTransfer pricing adjustment - TPO take the amount of ALP at NIL - determination of Management...The Transfer Pricing Officer (TPO) determined the Arm's Length Price (ALP) for a management consultancy fee at NIL, indicating no value. The decision involved a transfer pricing adjustment where foreign exchange loss in financial transactions was not recognized as a 'service charge' within intra-group services. ..... X X X X Extracts X X X X X X X X Extracts X X X X
|