Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Money-laundering prosecution is described as requiring a scheduled offence, proceeds of crime generated from that offence, and their projection as untainted, including knowing assistance in related processes. Challenges to investigation or discharge grounds in predicate offences are presented as outside the scope of the money-laundering proceeding. The notes explain that discharge requires assessment of a prima facie case and that strong suspicion may justify trial without a mini-trial. They also state that alleged defects in an authorised valuation report are evidentiary matters, and fresh expert valuation is not ordinarily required; loss quantification mainly concerns the predicate offence.
Money-laundering prosecution is described as requiring a scheduled offence, proceeds of crime generated from that offence, and their projection as untainted, including knowing assistance in related processes. Challenges to investigation or discharge grounds in predicate offences are presented as outside the scope of the money-laundering proceeding. The notes explain that discharge requires assessment of a prima facie case and that strong suspicion may justify trial without a mini-trial. They also state that alleged defects in an authorised valuation report are evidentiary matters, and fresh expert valuation is not ordinarily required; loss quantification mainly concerns the predicate offence.
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