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TP Adjustment - Notional interest on overdue receivables - ...


Transfer Pricing Adjustments Must Reflect Market Practices, Including Grace Periods for Overdue Receivables.

January 1, 2024

Case Laws     Income Tax     AT

TP Adjustment - Notional interest on overdue receivables - number of days outstanding beyond the grace period for each and every invoice. - If there are no agreements with the AEs, the TPO should consider the market practice in the relevant sector and then grant the grace period. We, however, clarify that in business world there is always a grace period and therefore non-granting of grace period is ignoring the business realities. - AT

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