TMI BlogContract Termination Fees Must Be Treated as Operating Revenue for Transfer Pricing Adjustments in International Transactions.Transfer pricing adjustment (TPA) - ALP determination - the contract termination fee also partakes the character of the contract receipt and is to be treated as operating revenue of the international transactions more particularly since the expenses incurred by the assessee on such contract has been taken as operating cost. - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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