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...
Redemption premium on foreign currency convertible bonds issued to raise and use business funds is characterised as revenue expenditure, because the liability arises on issuance and does not acquire a capital asset or enduring advantage. The notes state that expenditure connected with issuing debentures or obtaining loans is likewise revenue in nature. The premium liability arises in the year of issue and may be proportionately spread over the bonds' prescribed maturity period; it is immaterial whether redemption is at will or only at maturity. The text further records that no substantial question of law arose on either the revenue character or timing of the deduction.
Redemption premium on foreign currency convertible bonds issued to raise and use business funds is characterised as revenue expenditure, because the liability arises on issuance and does not acquire a capital asset or enduring advantage. The notes state that expenditure connected with issuing debentures or obtaining loans is likewise revenue in nature. The premium liability arises in the year of issue and may be proportionately spread over the bonds' prescribed maturity period; it is immaterial whether redemption is at will or only at maturity. The text further records that no substantial question of law arose on either the revenue character or timing of the deduction.
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