This Rule establishes the maximum allowable costs for design and consultancy expenses incurred abroad by an Incorporated Body under inspection. It specifies distinct percentage caps based on revenue for design and consultancy works. For design work, allowable costs are capped at 75% for head offices, 80% for related companies, and 85% for unrelated companies. For consultancy, the caps are 70%, 75%, and 80% respectively. The Rule mandates compliance with Article 37 for related party transactions, provides a formula to determine revenue when not specified, and requires separate treatment for exceptional cases after consulting the Tax Department.
Executive Rule No. 26 Design and consultancy expenses incurred abroad