Principal-agent characterization under Schedule I determines whether del credre credit interest is includible in transaction value. Classification of a del-credre agent depends on invoice issuance: if the supplier issues the invoice the DCA is not an agent; if the DCA invoices in its own name the DCA is an agent. If not an agent, the loan or credit extended by the DCA is an independent supply of services and interest charged is not included in the value of the supplier's goods. If the DCA is an agent, the temporary credit is subsumed in the supply of goods by the DCA and interest charged must be included in the transaction value of those goods.
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Provisions expressly mentioned in the judgment/order text.
Principal-agent characterization under Schedule I determines whether del credre credit interest is includible in transaction value.
Classification of a del-credre agent depends on invoice issuance: if the supplier issues the invoice the DCA is not an agent; if the DCA invoices in its own name the DCA is an agent. If not an agent, the loan or credit extended by the DCA is an independent supply of services and interest charged is not included in the value of the supplier's goods. If the DCA is an agent, the temporary credit is subsumed in the supply of goods by the DCA and interest charged must be included in the transaction value of those goods.
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