India - Ruling in Marubeni Case on Benchmarking and Determining Arm’s Length Consideration for the International Provision of Agency and Marketing Support Services
- V.T. Patel; K.P. Visharia
- International Transfer Pricing Journal, 2015 (Volume 22), No 5
- 10 September 2015
The authors analyse the Marubeni case concerning a typical business model and its nuances for benchmarking the international transaction of provision of agency and marketing support services, as well as the Court’s determination as to whether the consideration for such services was at arm’s length under the Income Tax Act, 1961.