[ compiled answer ]
law as at 14 Aug 2026 · administrative
What is the transfer pricing safe harbour floor for software development services?
The compiled answer
17% operating margin for software development / ITES where the transaction value is up to ₹100 crore; 18% above ₹100 crore; KPO 18–24% by employee-cost intensity (Rule 10TD). A margin below the floor is not protected — a validly elected margin at or above it forecloses TPO benchmarking of that transaction.
compiled value: 17
Pinpoint
Rule 10TD, Income-tax Rules
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/tp_safe_harbour_swd_floor.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)