Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Interest paid on delayed VAT was examined under the principle that business expenses must be incurred wholly and exclusively for business. Applying the precedent that interest on sales-tax arrears is compensatory rather than penal, the article concludes the assessing authorities erred in disallowing such interest; accordingly the interest debited in the profit and loss account should be allowed as a deductible business expenditure under section 37(1). The operative effect is allowance of the claimed deduction following the compensatory-interest characterisation.
Interest paid on delayed VAT was examined under the principle that business expenses must be incurred wholly and exclusively for business. Applying the precedent that interest on sales-tax arrears is compensatory rather than penal, the article concludes the assessing authorities erred in disallowing such interest; accordingly the interest debited in the profit and loss account should be allowed as a deductible business expenditure under section 37(1). The operative effect is allowance of the claimed deduction following the compensatory-interest characterisation.
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