TPO Cannot Unilaterally Separate and Benchmark Segmented AE Transactions at Nil Once TNMM Meets Arm’s Length Standard
TPO Cannot Unilaterally Separate and Benchmark Segmented AE Transactions at Nil Once TNMM Meets Arm’s Length Standard Issue Whether the Transfer Pricing Officer (TPO) can carve out IT support services (third-party software/licence costs) and benchmark a 5% markup separately at Nil after accepting the overall international transaction margins under the Transactional Net Margin Method (TNMM).… Read More »