TP Adjustment - Adjustment on account of provision of loan to ...

DRP Resolves Transfer Pricing Issue: 3% Markup on Loan Interest Rate for Associated Enterprises Based on Local Rates.

July 18, 2020

Case Laws Income Tax AT

TP Adjustment - Adjustment on account of provision of loan to AE’s - DRP adopted the interest rate at domestic cost of borrowing + 3% markup - rate of interest was to be determined on basis of rate prevailing in Country where loan had been consumed.

View Source

← Previous Next →

TP Adjustment - Adjustment on account of provision of loan to ...

DRP Resolves Transfer Pricing Issue: 3% Markup on Loan Interest Rate for Associated Enterprises Based on Local Rates.

July 18, 2020

Case Laws Income Tax AT

You may also like:

Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

TP Adjustment - Addition considering the interest free loan and advances to its Associated Enterprises - As assessee got such huge business from its associated...

TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

TP Adjustment - Interest on loans and advances given to the AEs - Interest rates vary and are thus dependent on the foreign currency in which the repayment is to be made...

The Principal Commissioner or Commissioner having jurisdiction over transfer pricing matters has been empowered, effective April 1, 2022, to invoke revisionary action...

TP Adjustment - ALP of interest on NDC’s [Non-convertible debentures] - NCD issued to associated enterprise is unsecured and loans taken from third parties are secured...

The ITAT Hyderabad addressed a Transfer Pricing (TP) Adjustment issue regarding interest on outstanding receivables, determining if it constitutes an international...

This summary discusses various transfer pricing and tax issues. It analyzes whether Advertisement, Marketing and Promotion (AMP) expenses incurred by the assessee were...

Interest on refund - Rate of interest - The rate of interest is statutorily prescribed under section 27 (A) read with Notification issued there under according to which...

The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The...

Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...

Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

Addition u/s 40A(2) - assessee has paid interest to certain related parties and treated interest rate @ 15% reasonable and disallowed excess rate paid to related parties...

Transfer Pricing Adjustment on account of interest on loans advanced to Associate Enterprise - interest rate charged by the assessee on the loan given should be...

TP Adjustment - Addition of interest expenses - These clauses in the loan agreement are nothing but eye-wash as the appellant company is the holding company of the...

Quick Updates: