Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Actuarial deficit contributions to an approved superannuation fund are characterised by their purpose. Contributions made to bridge actuarially determined deficits, including prior-year deficiencies, are ad hoc gap-filling payments rather than ordinary annual contributions subject to the Rule 87 ceiling or initial contributions. Recurrence of deficits does not alter that character. Applying the ceiling to contributions necessary to meet actuarial liabilities could impair the fund's solvency and conflict with the deduction scheme for approved superannuation funds. On that basis, disallowance of the actuarial deficit contributions was deleted and the revenue's appeal failed.
Actuarial deficit contributions to an approved superannuation fund are characterised by their purpose. Contributions made to bridge actuarially determined deficits, including prior-year deficiencies, are ad hoc gap-filling payments rather than ordinary annual contributions subject to the Rule 87 ceiling or initial contributions. Recurrence of deficits does not alter that character. Applying the ceiling to contributions necessary to meet actuarial liabilities could impair the fund's solvency and conflict with the deduction scheme for approved superannuation funds. On that basis, disallowance of the actuarial deficit contributions was deleted and the revenue's appeal failed.
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