Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Handheld mobile/portable computers used for warehousing, logistics, and inventory operations were assessed for tariff classification as smartphones or as automatic data processing machines under heading 8471. Applying Note 6(A) to Ch. 84, the devices were held to satisfy ADP criteria because they have sufficient RAM/storage, run programmable operating systems/software, perform user-specified arithmetical computations, and execute processing programs with logical decision-making without human intervention; barcode scanning and wireless connectivity were treated as ancillary. Notes 6(D) and 6(E) exclusions were found inapplicable, and cellular-call capability did not alter the principal ADP function. Consequently, the goods were classified under CTI/CTH 8471 30 90. - AAR
Handheld mobile/portable computers used for warehousing, logistics, and inventory operations were assessed for tariff classification as smartphones or as automatic data processing machines under heading 8471. Applying Note 6(A) to Ch. 84, the devices were held to satisfy ADP criteria because they have sufficient RAM/storage, run programmable operating systems/software, perform user-specified arithmetical computations, and execute processing programs with logical decision-making without human intervention; barcode scanning and wireless connectivity were treated as ancillary. Notes 6(D) and 6(E) exclusions were found inapplicable, and cellular-call capability did not alter the principal ADP function. Consequently, the goods were classified under CTI/CTH 8471 30 90. - AAR
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