Search - 包建铎违纪违法案件以案促改以案促治专题组织生活会 个人对照检查

Kundahar J, speaking for a panel of two, found that Columbia did not have a permanent establishment, stating (at para. 14): If the petitioner has to purchase goods for the purpose of export, an obligation is cast…to see that the goods…[are] acceptable to the customer outside India…Otherwise, the goods…may not find a customer outside India…[A]ll those acts are necessary to be performed …before export of goods…That liaison office is established only for the purpose of carrying on business of purchasing goods for the purpose of export and all that activity also falls within the meaning of the words “collecting information “ for the enterprise. ...

. … It is however also necessary to take account of the call options purchased by ESIP out of the sum paid by UBS for its subscription for the shares. ...

. … Nothing in this case justifies a different decision [than in BBM]. ...

In addition, Interoil provided the shareholders with considerable information on the value of the new Arrangement and the value of the contingent resources; b) the Transaction Committee was independent, examined and endorsed the arrangement; c) the Fairness Opinion was independent and addressed the deficiencies of the previous fairness opinion; d) the shareholders had access to dissent and appraisal remedies and those who indicated they wished dissent rights were reduced from 10% on the first plan of arrangement to 1 % on the new plan of arrangement. ...

. … The tax motivation is a fact. This fact constitutes a backdrop to take into account respecting the trust and its actual activities. ...

[A] document … had to be signed by each of the employees, confirming that they were familiar with the obligation…. ...

Before going on to find that SEL did not qualify as a “college…of…a university” for UK VAT purposes, Patten LJ stated (at paras 64-65): The word "college" … denotes a group of people organised as an institution usually (but not necessarily) in the field of education. ...

. … It is customary that the required work is subject to detailed quotations which provided a template for detailed steps to be performed. ...

. … [T]he object of ETA section 223 and QSTA section 425 is to permit the recipient from whom the taxes are collected to be apprised of the amounts owing for the supply and what are the payments due for each of the taxes so as permit it to receive credits to which it has a right upon being invoiced for those taxes. ...

., address for invoicing and of electricity use, late payment identification and telephone number) for all its commercial customers who were charged the regular electricity rate – so that CRA could compare this information with what it had in its own files. ...