Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Fully and compulsorily convertible debentures retain debt character until conversion, so pre-conversion interest cannot be benchmarked at nil by recharacterising them as equity. The transfer pricing authorities had not carried out an independent benchmarking exercise, so the arm's length price of the interest was remitted for fresh determination. For receivables from associated enterprises, notional interest was upheld in principle, but the adjustment had to be recomputed after allowing a 90-day credit period.
Fully and compulsorily convertible debentures retain debt character until conversion, so pre-conversion interest cannot be benchmarked at nil by recharacterising them as equity. The transfer pricing authorities had not carried out an independent benchmarking exercise, so the arm's length price of the interest was remitted for fresh determination. For receivables from associated enterprises, notional interest was upheld in principle, but the adjustment had to be recomputed after allowing a 90-day credit period.
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