Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Page of 4828
Press 'Enter' after typing page number.
2821 to 2840 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Demutualisation share transfers are to be taxed as long-term capital gains when the holding period and cost are determined by reference to pre-demutualisation membership; the statutory demutualisation cost rule requires adopting the original membership acquisition cost or its written down value as cost of acquisition, notwithstanding prior depreciation claimed on the membership card. The assessing officer's reliance on general short-term provisions is displaced by the specific demutualisation mechanism and binding precedent, leading to acceptance of original membership cost and long-term treatment of the gain.
Demutualisation share transfers are to be taxed as long-term capital gains when the holding period and cost are determined by reference to pre-demutualisation membership; the statutory demutualisation cost rule requires adopting the original membership acquisition cost or its written down value as cost of acquisition, notwithstanding prior depreciation claimed on the membership card. The assessing officer's reliance on general short-term provisions is displaced by the specific demutualisation mechanism and binding precedent, leading to acceptance of original membership cost and long-term treatment of the gain.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
