Avago Technologies Trading Ltd v/s Director General of the Mauritius Revenue Authority
The Applicant (Avago Technologies Trading Ltd) is a corporate entity in the chain of companies of the Avago Group. It is categorised as a GBL1 company in Mauritius and is a subsidiary to GEN IP (Singapore).
The Applicant is the main manufacturer of the Avago Group products for its affiliates and sells the finished products to its related parties. A License Agreement exist between GEN IP (Singapore) and the Applicant, which gives the right for the Applicant to hold Intellectual Property (IP) and distribute them to affiliated Contract Manufacturers and third-party Contract Manufacturers. Afterward, the Applicant sells finished products to another entity of the Avago Group only, known as “ATIS”.
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