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 - inclusion of interest on free loan - The cost of the bank guarantee is incurred by the appellant - Thus, there is no case to add an amount of notional interest in the value of taxable services rendered.
Valuation - inclusion of interest on free loan - The cost of the bank guarantee is incurred by the appellant - Thus, there is no case to add an amount of notional interest in the value of taxable services rendered.
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