Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Advance ruling jurisdiction was found unavailable where the applicant sought rulings on transportation, leasing and grazing-related services as a recipient rather than as the supplier liable to discharge tax. The Authority noted that questions on determination of tax liability and notification applicability must relate to services undertaken or proposed to be undertaken by the applicant, and that liability to pay tax vests with the service supplier. On that basis, the application was not admissible. The applicant then requested withdrawal, and the Authority recorded the request and disposed of the application as withdrawn without examining the merits.
Advance ruling jurisdiction was found unavailable where the applicant sought rulings on transportation, leasing and grazing-related services as a recipient rather than as the supplier liable to discharge tax. The Authority noted that questions on determination of tax liability and notification applicability must relate to services undertaken or proposed to be undertaken by the applicant, and that liability to pay tax vests with the service supplier. On that basis, the application was not admissible. The applicant then requested withdrawal, and the Authority recorded the request and disposed of the application as withdrawn without examining the merits.
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