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Indian Court Rules CUP as Best Transfer Pricing Method for Software Services

|Approved Changes|India
India

The Mumbai Income Tax Appellate Tribunal has recently ruled on whether the use of the comparable uncontrolled price (CUP) method or the transactional net margin method (TNMM) is better in regard to software services.

The case involved an Indian subsidiary that provided software services to its U.S parent company. In determining the appropriate transfer price, the subsidiary chose the CUP metho…

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