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...
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Non-compete fees paid - the three products of the company has advantage for seven years and the 4th product has advantage for fourteen years - payment is in the nature of capital expenditure - AT
Non-compete fees paid - the three products of the company has advantage for seven years and the 4th product has advantage for fourteen years - payment is in the nature of capital expenditure - AT
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