Brief facts: Some employees (management as well as non-management cadre) who are in the payroll of group companies are working for Parent company. Group companies recover cost of such employees from Parent company by raising debit note on actual cost basis. Issue: Whether reimbursement of salary paid by Parent company to group companies would be […]
Over the past few years issue of Advertisement, Marketing and Promotion (‘AMP’) expenses has become very prominent in Transfer Pricing Assessments in India, wherein Indian subsidiaries which are engaged in business activities using brand name of global multi-national enterprises (‘MNEs’). Indian Revenue Authorities (IRA) argues that AMP expenses involving brand promotion service by the taxpayer […]
