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...
Assessment of Firm as AOP - in terms of section 167 the share of the members of AOP are indeterminate - In such case the whole of the income of such an AOP is to be taxed at the maximum marginal rate, as being an AOP with indeterminate share - HC
Assessment of Firm as AOP - in terms of section 167 the share of the members of AOP are indeterminate - In such case the whole of the income of such an AOP is to be taxed at the maximum marginal rate, as being an AOP with indeterminate share - HC
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