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...
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TP Adjustment - Interest on delayed receivables - only two instances where there has been a marginal delay of 60 days and 26 days. Considering the nominal delay in the realization period and the overall average realization period being well before the grace period - there is no requirement to charge any interest towards receivables and, therefore, the TP adjustment made in this regard should be deleted - AT
TP Adjustment - Interest on delayed receivables - only two instances where there has been a marginal delay of 60 days and 26 days. Considering the nominal delay in the realization period and the overall average realization period being well before the grace period - there is no requirement to charge any interest towards receivables and, therefore, the TP adjustment made in this regard should be deleted - AT
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