Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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