Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights August 2020 Year 2020 This

TP Adjustment - arm’s length price of interest on short term ...


Interest Rate on Short-Term Loan to Associated Enterprise Aligns with Arm's Length Principles; No Adjustments Needed.

August 11, 2020

Case Laws     Income Tax     AT

TP Adjustment - arm’s length price of interest on short term loan granted to the AE - The fact that the assessee has provided a short term loan only for a period of 15 days to the AE has not been disputed. It is further noticed that assessee’s AE in Singapore has availed a loan from SBI, Singapore branch at interest rate of six months LIBOR plus 250 basis points. Considering the above, we are of the view that the rate of interest charged by the assessee is at arm's length requiring no further adjustment - AT

View Source

 


 

You may also like:

  1. TP adjustment - Arms’ length price of international transaction of overdue export proceeds - non-charging of interest on advances being overdue export proceeds from...

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

  3. TP Adjustment - interest charged on foreign currency loan - The Tribunal ruled in favor of the Assessee, finding that the interest charged on the loan to its Associated...

  4. 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...

  5. Transfer Pricing Adjustment - Arm's Length Adjustment to Income from Guarantee Commission - Income from Interest on Loans Advanced to Associated Enterprise - The...

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

  7. Transfer pricing adjustment on international transaction involving payment of guarantee fees to associated enterprise was held unjustified. Assessee demonstrated...

  8. TP Adjustment - Benchmarking of interest receivable on loan - when the assessee has charged higher interest on loan to subsidiary compared to the prevailing interest...

  9. TP adjustment - notional interest - short term advances made by the assessee to its associated enterprises - The assessee being unable to establish with evidence the...

  10. Allowability of Interest expenses @21.3% - unsecured redeemable cumulative non-convertible debentures - AO has compared the rate of interest paid on unsecured redeemable...

  11. 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...

  12. 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...

  13. The TPO benchmarked the ECB transaction using CUP method and SBI base rate as CUP, but failed to consider factors like credit rating, future revenue projections, and...

  14. TP adjustment - onsite development and project coordination fee’ - Associated enterprise can be considered as a tested party, in the present case. Accordingly, we direct...

  15. TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net...

 

Quick Updates:Latest Updates