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...
Treating the agreement for sale of land as sales - transfer of immovable property was considered to have taken place upon conveyancing and not the date of agreement of sale. - AT
Treating the agreement for sale of land as sales - transfer of immovable property was considered to have taken place upon conveyancing and not the date of agreement of sale. - AT
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