Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Export of services or not - The services being in relation to business or commerce, the question of their export would be decided on the basis of location of the person using these services for his business, not on the basis of place of performance - AT
Export of services or not - The services being in relation to business or commerce, the question of their export would be decided on the basis of location of the person using these services for his business, not on the basis of place of performance - AT
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