Transfer Pricing: Re-characterization of Software Developer as ‘Contract R&D Provider’ Rejected; BAPA and Past TPO Orders Confirm ‘Software Development’ Status
Transfer Pricing: Re-characterization of Software Developer as ‘Contract R&D Provider’ Rejected; BAPA and Past TPO Orders Confirm ‘Software Development’ Status ISSUE Whether the Transfer Pricing Officer (TPO) was justified in re-characterizing the assessee as a “Software Research/R&D Service Provider” (instead of a “Software Development Service Provider”) based on US tax documents, despite a signed Bilateral… Read More »
