Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Issue concerns classification of carbon pultruded plates and applicability of an exemption notification distinguishing raw carbon fibre from articles of carbon fibre. The analysis finds pultruded plates are resin-impregnated, cured, dimensionally stabilized articles (classified under tariff item 68151900) and thus not raw carbon fibre, so they do not qualify under the notification entry for raw carbon fibre. Applying the principle that a part of a part is a part of the whole, the plates used as spar caps are sub-parts of rotor blades and are inseparable in use; consequently they qualify as parts for rotor blade manufacture and attract the concessional basic customs duty rate under the exemption notification.
Issue concerns classification of carbon pultruded plates and applicability of an exemption notification distinguishing raw carbon fibre from articles of carbon fibre. The analysis finds pultruded plates are resin-impregnated, cured, dimensionally stabilized articles (classified under tariff item 68151900) and thus not raw carbon fibre, so they do not qualify under the notification entry for raw carbon fibre. Applying the principle that a part of a part is a part of the whole, the plates used as spar caps are sub-parts of rotor blades and are inseparable in use; consequently they qualify as parts for rotor blade manufacture and attract the concessional basic customs duty rate under the exemption notification.
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