Log in to Research Map for Income tax and follow these steps :
1. Start by finding cases with international transactions
- Search for the permanent establishment
- Search within the Search for associate enterprise within permanent establishment
2. To find cases related to arm’s length pricing (alp) with respect to royalty and fees for technical services
- Search for alp within the permanent establishment and associate enterprise
- Search for royalty payments within alp, permanent establishment and associate enterprise
- Search for FTS within alp, permanent establishment, associate enterprise and royalty payments
3. To further narrow down the results, use the section filters on the left
- Select section 92B
- From 4167 you will arrive at 6 results with a few clicks
Determine the arm’s length price for an international transaction within seconds