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EVOLUTION OF TAX: FROM DIGITS TO DIGITALISATION

I. Digitalisation and digital economy in India Digitalization is the adoption of digital technology in our everyday life. In a way, domains of our social life are...

ISSUES ON DETERMINING THE PLACE OF EFFECTIVE MANAGEMENT: IS INDIAâ S POEM STILL FINDING ITS RHYTHM

Abstract After its coming into effect around 2 years ago, the test of place of effective management (PoEM) is yet largely untested in India’s fiscal landscape and...

DIGITAL ECONOMY - THE EMERGING PE AND ATTRIBUTION ISSUES

1. Background Do you remember the first thing you ever bought or sold online? As we have been living in a digital economy for an entire generation, many of us would need to...

ADDRESSING TAX CHALLENGES IN DIGITALISED ECONOMY

Data and Profit Allocation 1. Introduction ‘Data is the new oil’ goes the saying. If data is so valuable, which it certainly is, then can the tax be far behind?...

ACCEPT-REJECT OF COMPARABLES-WHEN CAN IT CONSTITUTE A ‘SUBSTANTIAL QUESTION OF LAW’

Comparability analysis is one of the most critical aspects of Transfer Pricing benchmarking and therefore it comes as no surprise that selection of comparables has been one...

TAX DISPUTE RESOLUTION IN POST BEPS WORLD (ALTERNATIVE DISPUTE RESOLUTION MAP ADR)

Having shrugged of the possibility of effective and quick dispute resolution through the normal Court system, the whole world Intellectuals have been discussing the...

INDIAN MULTINATIONAL BUSINESS FAMILIES - GROWING COMPLEXITIES

The rapid growth of Indian family businesses in scale, size and reach has led to the emergence of 21st century Indian business families who have high aspirations and global...

INDIA-US SIGN INTER-GOVERNMENTAL AGREEMENT FOR EXCHANGE OF CBCR

Under Indian Transfer Pricing regulations constituent entities of multinationals groups must file a Country by Country Report ('CbCR') in India if the MNE has consolidated...

FORTIFYING THE DIMENSION OF SECTION 56(1)

The legislative intent of the Income-tax Act, 1961 (Act) has always been providing taxation of income. The term “income” is defined under the provisions of the...

OPTIONS WITH FOREIGN INVESTORS TO ACCESS CORPORATE DEBT IN INDIA

Historically, accessing Indian debt for foreign investors has been a tough task with a plethora of regulations along with restrictions on, inter-alia, use, and interest...

THE VALUATION CONUNDRUM – INTERPLAY WITH TAX AND REGULATORY FACETS

In today's world, it may be apt to mention that "value" lies in the eyes of the beholder. Sporadic spike in prices of stocks and securities as well as sudden plunges in...

REPORT ON TAXING DIGITAL ECONOMY IN INDIA: THE WAY FORWARD

Features of businesses in the digital landscape are vastly different from those of typical brick and mortar businesses. These features include mobility, reliance on data,...

CROSS BORDER INSOLVENCY LAW IN INDIA

The Insolvency and Bankruptcy code, 2016 (“Code”) came in existence on 28th May 2016. After Goods and Services Tax Act, 2017 it is seen as next big...

New ways of business giving rise to new ways of Taxation - Significant Economic Presence

Challenges pertaining to taxation of digital transactions The evolution of business models in general, and the growth of the digital economy in particular, have resulted...

Revised ECB framework eases access to foreign debt for Indian businesses

As part of the Central Government's pursuit to improve ease of doing business in India, the Reserve Bank of India (RBI), on the basis of notification no. FEMA.3R/2018-RB...

Regulatory framework for FPI investment in corporate debt: Recent changes

Under Indian exchange control regulations, typically, foreign investment is permissible only in equity shares and instruments that are fully and mandatorily convertible to...

Angel Tax Tangle

In a bid to start their own business ventures, many entrepreneurs have formed start-ups. Governments from across the world have been going out of their way to facilitate...

FOREIGN COMPANIES : RISK OF INDIAN TAX EXPOSURE

The Indian tax authorities are generally seen to be extra vigilant in scrutinizing the transactions undertaken by non-residents in India. Primarily this may be because the...

RECENT TRIBUNAL RULING (SULZER PUMPS) ON CONTRACT MANUFACTURING OPERATIONS

Recently, Mumbai Tribunal in Sulzer pumps India Pvt. Ltd. (2018) 54 CCH 543 MumTrib, had the occasion to distinguish between a ‘contract manufacturer’ and...

RECENT TAX DEVELOPMENTS AND THEIR IMPACT ON MNCS OPERATING IN INDIA

Background With the advent of globalisation and increasing market presence of Indian middle-class, the presence of MNCs in developing countries viz India have become a norm...