Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Royalty and licence fees may be included in the customs transaction value only where Revenue establishes a direct and proximate relationship with the imported goods and proves that payment is a condition of their sale. The explanation concerning post-import processing does not independently expand these requirements. Royalties payable for technology transfer, intellectual property, or post-import manufacturing rights are not linked to imports merely through a broad commercial connection. Where royalty arises from manufacture and sale of finished products, is neither conditional on component imports nor calculated by their value or quantity, it is not includible in the assessable value of imported components.
Royalty and licence fees may be included in the customs transaction value only where Revenue establishes a direct and proximate relationship with the imported goods and proves that payment is a condition of their sale. The explanation concerning post-import processing does not independently expand these requirements. Royalties payable for technology transfer, intellectual property, or post-import manufacturing rights are not linked to imports merely through a broad commercial connection. Where royalty arises from manufacture and sale of finished products, is neither conditional on component imports nor calculated by their value or quantity, it is not includible in the assessable value of imported components.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
