Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Status quo over the company's assets continues pending valuation and determination of the proposed buyout of the appellant's shareholding. As the remaining dispute concerned alternative buyout relief, and the parties had proposed valuers but no appointment or valuation report had been made, the Tribunal was to appoint a valuer, obtain the report, and independently decide the buyout offer expeditiously. The company appeal was disposed of subject to continuation of the existing status quo until that process is completed.
Status quo over the company's assets continues pending valuation and determination of the proposed buyout of the appellant's shareholding. As the remaining dispute concerned alternative buyout relief, and the parties had proposed valuers but no appointment or valuation report had been made, the Tribunal was to appoint a valuer, obtain the report, and independently decide the buyout offer expeditiously. The company appeal was disposed of subject to continuation of the existing status quo until that process is completed.
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