The CBDT has issued Notification No. 46/2017/ F. No. 370142/6/2017-TPL dated 07.06.2017 by which it has amended the Safe Harbour Rules specified in the Income-tax Rules relating to transfer pricing for international transactions. The “safe harbours” stipulate circumstances in which the Transfer Pricing Officer (TPO) will accept the transfer price declared by the assessee. The Notification has added a category of international transaction being receipts of “low value-adding intra-group services”. The prevalent safe harbour margins have also been revised. The new Rules will go a long way to avoid disputes between the income-tax department and the assessees. All taxpayers and tax professionals are required to be well-versed with the terms of the safe harbour rules
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