In our Transfer Pricing world, the OECD has duly acknowledged the fact that the business environment has evolved due to change in technology and digitalization. The efforts of OECD to walk hand in hand with the ongoing evolution of technology is visible from its work in Action 1 – Digitalisation, Business Models and Value Creation, where it is trying to justify its underlying principle need to align transfer pricing outcome with value creation
The Indian Business Support Services industry may soon face a setback due to the recent ruling of Authority of Advance Ruling in the case of M/s Vserv Global Private Limited
As per current Income Tax provisions, if a closely-held company i.e. a company in which public is not substantially interested, issues shares at a price which is more than its fair market value (FMV), then the excess amount i.e. excess of issue price over fair market value will be taxed as income from other sources in the hands of the company.
Anurag Agrawal Introduction Over several decades and in step with the globalisation of the economy, intra group transactions have grown exponentially world-wide especially related to intangible assets. The word “intangible asset” is intended to address something which is not a physical asset or a financial asset, which is capable of being owned or controlled for […]
