Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Provisional attachment under money laundering law was sustained where the Tribunal held that the attachment was confined to the accused co-owner's share and did not extend to the non-accused spouse's interest. It further held that property of equivalent value could be attached when the alleged proceeds of crime had been dissipated or were no longer available, and that prior purchase or disclosed source of funds did not defeat such attachment on the facts. The confirmation of the provisional attachment order was therefore upheld and the appeals were dismissed.
Provisional attachment under money laundering law was sustained where the Tribunal held that the attachment was confined to the accused co-owner's share and did not extend to the non-accused spouse's interest. It further held that property of equivalent value could be attached when the alleged proceeds of crime had been dissipated or were no longer available, and that prior purchase or disclosed source of funds did not defeat such attachment on the facts. The confirmation of the provisional attachment order was therefore upheld and the appeals were dismissed.
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