TMI BlogArm's Length Price for Importing Capital Equipment Must Reflect Costs, Including Depreciation; Cannot Be Set to Nil.Determination of ALP - in case of service provider, the ALP of import of capital equipment, the depreciation cost of which is recharged with a markup cannot be determined to be nil because it is a tax neutral transaction and revenue is dependent upon the cost incurred (which includes depreciation). ..... X X X X Extracts X X X X X X X X Extracts X X X X
|