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TAXATION, TRANSFER PRICING AND DIGITALIZATION
The article highlights the importance of seeking a fresh look at the issues of transfer pricing. The challenges in the area of taxing the digital transactions both in the...
IS THE GLOBAL SYSTEM MOVING TOWARDS FORMULARY APPORTIONMENT AS AN ALTERNATIVE INTERNATIONAL TAXATION APPROACH
The Arms Length Principle (ALP) has been the fundamental tool in determining fairness of taxation amongst various tax locations for the past several decades. However due to...
DEEMED DIVIDEND UNDER INCOME TAX ACT, 1961
The provisions of Section 2(22)(e) deems certain payments to be dividend on the fulfillment of certain conditions. The amount of deemed dividend is restricted to the extent...
CBDTs FINAL NOTIFICATION BRINGS RELIEF IN CASE OF NON-STT PAID TRANSACTIONS
Long term capital gains from sale of equity instruments now taxable at 10% mandate the payment of STT to claim the concessional tax rate, the Final Notification issued by...
NCLT UNFOLDS A NEW ANGLE TO USUAL M&A DEALS
Chennai Bench of NCLT recently flagged unaccustomed but welcoming angle to M&A deals by approving merger of a LLP with a company. The Bench emphasised on the intent of the...
THIS TIME POEM SEEMS TO FIND THE RIGHT RHYTHM
On 22 June, 2018, the Central Board of Direct Taxes (CBDT) issued the final notification prescribing guidelines on taxation of foreign companies that are subject to tax in...
RELEVANCE OF PE & INTANGIBLES TO BUSINESS RESTRUCTURING DECISIONS
It has been an age old tradition where companies work around the tax legislations to develop and implement a combination of tax planning strategies to park their profits in...
FUTURE OF LITIGATION - DRP, APA, MAP AND ARBITRATION
Direct tax collection in India in Financial Year (â FYâ ) 2002-03 was INR 83,088 Crores (INR 830.88 billion)
TRANSFER PRICING DISPUTE ON â MARKETING INTANGIBLESâ IN THE POST BEPS SCENARIO
India has emerged as the leading jurisdiction in terms of transfer pricing litigation and jurisprudence. The Indian transfer pricing landscape thus far is characterised by...
TRANSFER PRICING ASPECTS OF BUSINESS RESTRUCTURING
Transfer pricing is an art and not an exact science. Indian TP regulations and also international practices in the transfer pricing arena are fast evolving.
GAAR PANEL OPINIONS
This article comments on the eleven case case-specific opinions so far released by the Panel established for the purposes of the General Anti-Abuse Rule (respectively "the...
THE GENERAL ANTI AVOIDANCE RULES (GAAR): THE GLOBAL PERSPECTIVE IN INDIAN CONTEXT
Over last few years, the tax authorities from over 100 countries have actively participated in the OECDâ s mega project for countering Base Erosion and Profit Shifting...
TAXATION OF DIGITAL ECONOMY â GLOBAL DEVELOPMENTS
Advent of digitization, has drastically overhauled the way of doing business as we know it.
TAXING DIGITAL ECONOMY - APPLICABILITY OF NON-DISCRIMINATION RULES IN INTERNATIONAL AGREEMENTS
The Report on Digital Economy as part of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project has articulated the concerns of various countries across the world...
BEPS ACTION 7: PREVENTING THE ARTIFICIAL AVOIDANCE OF PERMANENT ESTABLISHMENT STATUS
We are living in an age wherein businesses have transcended boundaries and have made the world a global village.
COMMISSIONAIRE STRUCTURES AND THEIR FUTURE AFTER BEPS ACTION PLAN 7
In mainland Europe, a â commissionaireâ is an attendant, messenger or subordinate employed in hotels, whose chief duty is to attend at railway stations, secure...
BEPS ACTION 13 - WHAT IS THE FUTURE OF TP DOCUMENTATION
In October 2015, the Organisation for Economic Cooperation and Development (OECD) released the final reports on its Base Erosion and Profit Shifting (BEPS) project.
TAKING STOCK OF U.S. â TAX REFORMâ AS THE DUST SETTLES
After a year of speculation about the legislative capabilities of a Republican-held Congress, the United States has managed to pass its first major tax bill in three decades.
US TAX REFORMS â WHATâ S IN STORE FOR INDIAN BUSINESSES
The Tax Cut and Jobs Act, 2017, which received President Trumpâ s sign-off on 22 December last year, gave way to Americaâ s biggest overhaul of its federal income tax...
US TAX REFORMS â AN INDIAN PERSPECTIVE
The Tax Cuts and Jobs Act, 2017, commonly referred to as the US Tax Reforms are intended to make US more competitive in the international market.
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