Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
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...
Hookah service in designated smoking areas is absolutely prohibited: the post-2017 replacement of "no other service" with "no service" bars every form of service, including self-service or purported rental models. Preparing, supplying, operating, or maintaining hookah for consideration remains a service because its use requires apparatus and technical assistance; patrons lack the unrestricted possession and control required for a rental. Food-safety law does not cover tobacco products, and municipal law provides no separate hookah-licensing power. Police may enforce smoking-in-public-place and tobacco-sale restrictions through statutory search, seizure, confiscation, and penalty powers.
Hookah service in designated smoking areas is absolutely prohibited: the post-2017 replacement of "no other service" with "no service" bars every form of service, including self-service or purported rental models. Preparing, supplying, operating, or maintaining hookah for consideration remains a service because its use requires apparatus and technical assistance; patrons lack the unrestricted possession and control required for a rental. Food-safety law does not cover tobacco products, and municipal law provides no separate hookah-licensing power. Police may enforce smoking-in-public-place and tobacco-sale restrictions through statutory search, seizure, confiscation, and penalty powers.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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