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...
Valuation - Clearance to inter-connected undertakings - merely because the units are interconnected undertakings the same would not be a ground to reject the transaction value unless the units are related persons. - AT
Valuation - Clearance to inter-connected undertakings - merely because the units are interconnected undertakings the same would not be a ground to reject the transaction value unless the units are related persons. - AT
Note: It is a system-generated summary and is for quick reference only.