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...
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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