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Tax authority was not authorized to discard the associated entity and treat Pakistani PE as the PE of offshore supplier for invoking force of attraction rule.The requirement to obtain specific withholding tax exemption was inapplicable in case of payments for import of goods where title to goods is transferred outside Pakistan and supply is not made between associates.Lastly, the tax authority maintained that the offshore contract is subject to tax in Pakistan as per DTT between Pakistan and China, which is based on the UN Model Tax Convention (UN MTC) and contains a ‘force of attraction’ rule.ĪTIR decided the appeal in favor of the taxpayer and relied on precedents involving DTTs with Germany and Italy to conclude that offshore supply contract/portion of composite contract cannot be subject to tax in Pakistan due to overriding effect of relevant DTTs. The tax authority inferred that the offshore supplier and onshore service provider, being PE of a separate company of the same group, must be considered a single entity for tax purposes. The contract is essentially in the nature of an EPC contract and the location split of the EPC contract was made to avoid taxes due in Pakistan.Both offshore and onshore agreements were similar in language and signed by the same person.The supplier of machinery and the provider of onshore service were associates.
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The taxpayer was held assessee-in-default due to the following facts: The onshore contract (construction, assembly and installation services) was signed separately with an associate of the equipment supplier, also resident in China and executed through a branch office registered in Pakistan, constituting a permanent establishment (PE). As per the facts, the appellant, a Pakistani renewable energy project, imported machinery and equipment from a Chinese manufacturer. Recently, Pakistan’s Appellate Tribunal Inland Revenue (ATIR – second tier appeal forum) has allowed an appeal against the tax authority’s order for recovery of withholding tax, deductible while making payment for the offshore supply of machinery (ITA 377/KB/2019). The tax implications for these transactions are influenced by the design of the transaction in question and the provisions of the applicable Double Tax Treaties (DTTs).
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Christie’s Geneva to Auction the Only Known Patek Philippe ref.Franck Muller x Bamford Watch Department Popeye inspired Vanguard.Franck Muller Vanguard Colorado Grand Collection.
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Ulysse Nardin Marine Torpilleur Dual Time 44mm.Seiko 5 Sports x Honda Super Cub Limited Edition.Seiko Prospex Speedtimer Solar Chronographs, references SSC911, SSC913 and SSC915.Grand Seiko Kodo Constant-Force Tourbillon SLGT001 Unique Piece.
Bram ramon price series#
Christopher Ward Military Collection Series 2.Hublot Big Bang Unico Gourmet Limited Edition.Hublot Big Bang e FIFA World Cup Qatar 2022™.Triangular cut, bringing to life sharp angles capable of catching the light Gothic-inspired engraving made by Bram Ramon using a new technique, the “Prisma Cut”ĭeep chiselled who reveal both shape and colour Two non-reflective sapphire crystals, front and backĭial and bezel are Hand engraved with 24cts gold inlay
Bram ramon price manual#
Slipping gold leaf into the recesses of key sculpted motifs adds exceptional depth to the Brabant, whose colours range through every shade of grey to black and gold.Įxclusive ArtyA flying tourbillon manual winding Pushing the envelope still further, ArtyA and Bram Ramon have added 24-carat gold inserts to the composition. The ArtyA Brabant exudes historic style notes, a Gothic spirit, a hint of religion, and a Flemish touch –and the whole is far greater than the sum of all these parts. Another new feature is that the cut is triangular, bringing to life sharp angles capable of catching the light. It involves the material being especially deeply chiselled (thereby combining sculpture and engraving) to reveal both shape and colour. Bram Ramon has dubbed his very own technique the “Prisma cut”.
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