Mandatory ISD may subsidize the benefits provided in recent circulars on intra-entity valuation

The ISD provision will be mandatory starting April 2025. This effectively introduces a sunset clause for Circulars 199 and 210 (although not intra-entity), as businesses may no longer be able to leverage lesser invoice values or scenarios with no invoices as outlined in these circulars.

While activities outside the ISD framework can still benefit from these circulars, businesses planning to make use of the same for future transactions will need to re-examine their strategies in light of the mandatory ISD requirement.