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Learn about the MFN (Most Favored Nation) Clause in Double Tax Avoidance Agreements, its recent controversy, and the Supreme Court’s clarification on its operation. Analysis and impact included.
What is Transfer Pricing? Transfer pricing is an accounting practice followed to establish an agreed price at Arm’s length during a transaction between associated enterprises. The transactions can be in terms of goods and services. There are five methods which can be used to get to the agreed price where the profits are divided fairly […]
The Ministry of Finance’s concerns regarding possible tax avoidance practices by manipulations in the prices charged or paid, in intra-group transactions, started increasing gradually with the increase in the economic activity reported by these Multi-National Companies. These concerns prompted the then Indian Government to eventually introduce the Transfer Pricing (TP) Regulations via The Finance Bill (2001).
FM started by stating that our Prime Minister has always been on the side of reform for better ease of living in the country. She added that the Prime Minister has laid out a vision after several discussions at various levels. Inputs obtained were given due consideration. This is to spur growth and built a […]
The Coronavirus (‘COVID-19’) pandemic has already caused major health crisis in almost entire world and has led to disruption of the global economy. The situation has resulted in economic slowdown and is likely to get worse in coming time. The International Monetary Fund (‘IMF’) has stated that the global economy has already entered into a […]
As per section 2(42C) of the Income-tax Act 1961, ‘Slump Sale’ means the transfer of one or more undertakings as a result of the sale for a lump sum consideration without values being assigned to the individual assets and liabilities in such sales. For understanding the term ‘Slump Sale’, it is significant to delve into […]
Article explains and compares Governing Section, Meaning, Applicability, Conditions / Restriction, Pricing / Valuation Report for issue of share capital under Rights Issue, Employee Stock Option Scheme, Sweat Equity Shares and Preferential Issue. A Comparative Chart showing the different ways of issue of share capital under Rights Issue, Employee Stock Option Scheme, Sweat Equity Shares […]
There could be tax implications on the conversion of a Company into LLP (for transfer of business) in the hands of LLP and on its shareholders (for extinguishment of shares held in such Company). The Income-tax Act, 1961 (IT Act) contains specific provisions governing tax implications in case of conversion of a Private Limited Company […]
1. Start-ups – The existing provisions of section 80-IAC of the Act provide for a deduction of an amount equal to one hundred per cent of the profits and gains derived from an eligible business by an eligible start-up for three consecutive assessment years out of seven years, at the option of the assessee, subject […]
