Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Digital advertising and sales-promotion expenditure on media space, SMS broadcasts, search-engine optimisation, campaign content, marketing videos and social-media strategy is revenue expenditure where it comprises recurring promotional measures, creates no business asset and only improves product promotion through a digital platform. The enduring-benefit test does not make such expenditure capital without an asset or capital-field advantage. Payments for website and mobile-app search services are likewise revenue expenditure where they improve product searches, correct search terms and facilitate sales without creating a capital asset or enduring capital advantage. Disallowances of both categories were deleted; the Revenue's appeals failed and supportive cross-objections became infructuous.
Digital advertising and sales-promotion expenditure on media space, SMS broadcasts, search-engine optimisation, campaign content, marketing videos and social-media strategy is revenue expenditure where it comprises recurring promotional measures, creates no business asset and only improves product promotion through a digital platform. The enduring-benefit test does not make such expenditure capital without an asset or capital-field advantage. Payments for website and mobile-app search services are likewise revenue expenditure where they improve product searches, correct search terms and facilitate sales without creating a capital asset or enduring capital advantage. Disallowances of both categories were deleted; the Revenue's appeals failed and supportive cross-objections became infructuous.
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