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...
Denial of area based exemption - if the exemption is extended to one unit, the change in its ownership would not jeopardize the admissibility of exemption for remaining part of the period - AT
Denial of area based exemption - if the exemption is extended to one unit, the change in its ownership would not jeopardize the admissibility of exemption for remaining part of the period - AT
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