TP Adjustment - Upward adjustment of Arm’s Length Price in ...

Arm's Length Price Upheld for Management Services; No Extra Transfer Pricing Adjustments Needed.

January 18, 2024

Case Laws Income Tax AT

TP Adjustment - Upward adjustment of Arm’s Length Price in respect of Management Services - These services are not in the nature of stewardship or shareholder activity. The payment to Schaeffler Holding (China) Co. Ltd. at the actual costs incurred in providing such services plus 5% mark-up is at ALP, which does not require any transfer pricing addition. - AT

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TP Adjustment - Upward adjustment of Arm’s Length Price in ...

Arm's Length Price Upheld for Management Services; No Extra Transfer Pricing Adjustments Needed.

January 18, 2024

Case Laws Income Tax AT

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