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...
Disallowing the claim derivative loss as speculation loss - once the approval is granted in the relevant previous year the approval has to be taken as effective from the beginning of the relevant year - AT
Disallowing the claim derivative loss as speculation loss - once the approval is granted in the relevant previous year the approval has to be taken as effective from the beginning of the relevant year - AT
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