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...
Undervaluation of goods - Mutuality of interest - interconnected undertaking - Burden of proof - Mere allegation that there was mutuality of interest remained unproved when burden of proof was on Revenue in this regard - AT
Undervaluation of goods - Mutuality of interest - interconnected undertaking - Burden of proof - Mere allegation that there was mutuality of interest remained unproved when burden of proof was on Revenue in this regard - AT
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