Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Assessable Value of Goods – inclusion of fee payable by the appellants for the Sole Distribution Rights - the department could not show any evidence that the aforesaid fee was liable to be loaded in terms of Rule 10(1)(d) - demand set aside - AT
Assessable Value of Goods – inclusion of fee payable by the appellants for the Sole Distribution Rights - the department could not show any evidence that the aforesaid fee was liable to be loaded in terms of Rule 10(1)(d) - demand set aside - AT
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