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Broker assuming all risks without any right to conclude contracts on behalf of NR can’t be treated as agency PE

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  • Broker assuming all risks without any right to conclude contracts on behalf of NR can’t be treated as agency PE
Posted onon September 16, 2014

Tenet Tax Daily September 16 2014

By tenettax-team
Corporate Tax, International Tax

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Transaction between two resident entities won’t be an ‘International transaction’; no additions to be made
Re-assessment affirmed as commission paid to foreign agent was included in cost of asset to escape TDS liability

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