Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Applying the General Rules of Interpretation and Section XVI Note 3, the principal-function test was used to classify a composite tracking device composed of a GPS receiver, sensors and a modem. The device's dominant commercial purpose and essential character derive from GPS-based determination of geographic position; sensors and modem were held ancillary because they supply supplementary metrics and relay GPS-derived data. Accordingly, the device is classifiable as radio navigational aid apparatus and assigned to tariff subheading 8526 91 90 as other radio navigational aid apparatus.
Applying the General Rules of Interpretation and Section XVI Note 3, the principal-function test was used to classify a composite tracking device composed of a GPS receiver, sensors and a modem. The device's dominant commercial purpose and essential character derive from GPS-based determination of geographic position; sensors and modem were held ancillary because they supply supplementary metrics and relay GPS-derived data. Accordingly, the device is classifiable as radio navigational aid apparatus and assigned to tariff subheading 8526 91 90 as other radio navigational aid apparatus.
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