Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
Specific customs headings for scaffolding components prevail over general classification, invalidating misclassification proceedings and enabling with...
Sales commission paid to an associated enterprise was supported by a written inter-company agreement and export-chain records, including purchase orders, supply instructions, invoices and shipping documents. The commission was linked to sales procured through the associated enterprise and became payable after third-party supply orders were received; the arm's length price was therefore not treated as nil. For delayed associated-enterprise receivables, the accepted TNMM operating margin and working-capital adjustment were considered to neutralise delayed realisation. As no differential credit benefit or real, determinable notional income was shown, a separate notional-interest adjustment was considered unwarranted. Both transfer-pricing adjustments were deleted.
Sales commission paid to an associated enterprise was supported by a written inter-company agreement and export-chain records, including purchase orders, supply instructions, invoices and shipping documents. The commission was linked to sales procured through the associated enterprise and became payable after third-party supply orders were received; the arm's length price was therefore not treated as nil. For delayed associated-enterprise receivables, the accepted TNMM operating margin and working-capital adjustment were considered to neutralise delayed realisation. As no differential credit benefit or real, determinable notional income was shown, a separate notional-interest adjustment was considered unwarranted. Both transfer-pricing adjustments were deleted.
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