Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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