Nil Arm’s Length Price Determination for Intra-Group Services Without Proper Benchmarking Analysis Is Unsustainable
Nil Arm’s Length Price Determination for Intra-Group Services Without Proper Benchmarking Analysis Is Unsustainable Issue Whether determining the Arm’s Length Price (ALP) of intra-group services (Global Information Services, Management Service Fee, and Multinational Client Coordination) at nil is legally sustainable based merely on the absence of a demonstrated commercial benefit, and whether disallowance under Section… Read More »