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...
TP adjustment - comparable selection - RTP - the %age of RPT is determined based on the availability of comparables - The more we restrict, chances of loosing reasonable comparability is more
TP adjustment - comparable selection - RTP - the %age of RPT is determined based on the availability of comparables - The more we restrict, chances of loosing reasonable comparability is more
Note: It is a system-generated summary and is for quick reference only.