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...
Transfer pricing adjustment - adjustment made on account of sharing of software expenses with the AE - no reason why adjustment should be made on account of sharing of software expenses with the AE. The TPO has also not given any reason to treat the subscription value as nil. - AT
Transfer pricing adjustment - adjustment made on account of sharing of software expenses with the AE - no reason why adjustment should be made on account of sharing of software expenses with the AE. The TPO has also not given any reason to treat the subscription value as nil. - AT
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