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Merely assisting a non-resident principal would not cause an agent to be considered as PE
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International Tax
Merely assisting a non-resident principal would not cause an agent to be considered as PE
Posted on
on
June 26, 2013
Tenet Tax Daily June 13 2013
By
tenettax-team
International Tax
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Product similarity is must for applying CUP method, not for TNMM.
Once a transaction is genuine and traded at proper valuation, even if it is entered with a motive to avoid tax, it would not become a colorable device
