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Singapore issues TP Guidelines for activities undertaken by Singapore based HQs or regional Hubs for APAC region. The said guidelines provide for the determination of remuneration for such hubs/ HQs on arm's length basis.
The controversy surrounding the taxation of payments for computer software in international transactions has been a subject matter of extensive litigation for over two decades in India.
The concept of Significant Economic Presence (�SEP�) was introduced in the Income-Tax Act, 1961 (�the Act�) from April 1, 2018 i.e. A.Y.
Section 23(5) of the Income Tax Act -Explained
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