Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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