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...
Undervaluation - mis-declaration - there is no reference to any evidence on record to create a doubt about transaction value or to believe the certificate given by the foreign supplier - AT
Undervaluation - mis-declaration - there is no reference to any evidence on record to create a doubt about transaction value or to believe the certificate given by the foreign supplier - AT
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