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...
Franchisee Service - Amount received from affiliates being RCs and LCs - Scope of the MOU - Indeed, the MOU in question is so clear an example of “franchise” as defined in Section 65 (47) ibid that any further elaboration on this point will be an exercise in over-kill. - AT
Franchisee Service - Amount received from affiliates being RCs and LCs - Scope of the MOU - Indeed, the MOU in question is so clear an example of “franchise” as defined in Section 65 (47) ibid that any further elaboration on this point will be an exercise in over-kill. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
