Intra-group services have been an area of significant focus by the Indian revenue officers. During audit, it is typical that, as Indian regulations do not specifically provide for detailed rules for treatment of management charges, the revenue officers generally follow the principles enunciated in the OECD guidelines.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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