Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Challenge concerned issuance of a withholding tax certificate at 15% instead of a requested NIL certificate for a UK-incorporated company under Section 197; the text emphasises that orders under Section 197 operate as advance tax and are refundable if not exigible, but that accepting Revenue's position would defeat the provision's purpose. The account notes significant delay between application and order, during which tax was deducted. The operative outcome recorded is quashing of the impugned order and direction to issue a NIL-rate certificate for the relevant assessment year within fifteen days and to continue issuing annual NIL certificates within thirty days of future applications.
Challenge concerned issuance of a withholding tax certificate at 15% instead of a requested NIL certificate for a UK-incorporated company under Section 197; the text emphasises that orders under Section 197 operate as advance tax and are refundable if not exigible, but that accepting Revenue's position would defeat the provision's purpose. The account notes significant delay between application and order, during which tax was deducted. The operative outcome recorded is quashing of the impugned order and direction to issue a NIL-rate certificate for the relevant assessment year within fifteen days and to continue issuing annual NIL certificates within thirty days of future applications.
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