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...
Transferable DFIA licences remained valid despite penalties imposed on the exporter, as they were not cancelled. The text explains that where proceedings against the exporter resulted in the duty demand being dropped and allegations against the importer were unproved, the importer could not be treated as having used fraudulent means to make duty-free imports. Those circumstances also did not justify invoking the extended limitation period. The customs-duty demand was therefore dropped, and the Revenue's appeal against that outcome was dismissed.
Transferable DFIA licences remained valid despite penalties imposed on the exporter, as they were not cancelled. The text explains that where proceedings against the exporter resulted in the duty demand being dropped and allegations against the importer were unproved, the importer could not be treated as having used fraudulent means to make duty-free imports. Those circumstances also did not justify invoking the extended limitation period. The customs-duty demand was therefore dropped, and the Revenue's appeal against that outcome was dismissed.
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