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...
Valuation of services - Joint venture - inclusion of "cost petroleum" and "profit petroleum" as per the Production sharing contract - inclusion of cash calls in the assessable value or not - Providing mining services to government - there is no service provider and service recipient relationship in the joint venture and the amounts in the nature of profit petroleum/cost petroleum/ cash calls are not consideration for services. - AT
Valuation of services - Joint venture - inclusion of "cost petroleum" and "profit petroleum" as per the Production sharing contract - inclusion of cash calls in the assessable value or not - Providing mining services to government - there is no service provider and service recipient relationship in the joint venture and the amounts in the nature of profit petroleum/cost petroleum/ cash calls are not consideration for services. - AT
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