Consider these transactions between an Indian company and its non-resident associated enterprise: 1. a licence to use a trademark; 2. the provision of marketing services; 3. a short-term loan. Which…

Section 163(1) of the Income-tax Act, 2025 includes the purchase, sale, transfer, lease or use of intangible property such as trademarks, the provision of services including marketing, and lending or borrowing of money of any term. All three therefore fall within the definition; a loan is covered whether it is long-term or short-term.