TMI BlogExistence of a Permanent Establishment – Article 7 of the DTAA with France - the initial onus is upon...Existence of a Permanent Establishment – Article 7 of the DTAA with France - the initial onus is upon the Revenue to show that the transactions are not at arm's length price, this aspect has not been looked upon by the Revenue authorities - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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