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Hritik Raina

Latest Posts by Hritik Raina

Computing trading income & deductible expense for income tax in UK

February 29, 2024 363 Views 0 comment Print

Explore the complexities of computing trading income and deductible expenses for UK income tax, including the role of GAAP, statutory provisions, and tax law adjustments.

Tackling Tax Avoidance in UK: Ramsay doctrine and General Anti-Avoidance Rule (‘GAAR’)

February 23, 2024 390 Views 0 comment Print

Learn about tackling tax avoidance in the UK with the Ramsay doctrine and GAAR. Explore their implications and effectiveness in combating tax avoidance strategies.

Correct application of ‘source’ principle: Ardmore Construction Ltd v HMRC [2018] EWCA Civ 1438

February 22, 2024 342 Views 0 comment Print

Analyzing the Ardmore Construction Ltd v HMRC case on the UK’s “source” principle in taxation, highlighting the court’s stance on income origin for tax purposes.

Evolution of OECD’s concept of Harmful Tax Practices: From 1998 Report to BEPS Action 5 Approach

February 21, 2024 375 Views 0 comment Print

Explore the evolution of harmful tax practices from the OECD’s 1998 report to the BEPS Action 5 approach, focusing on transparency, substantial activity requirements, and the eradication of harmful regimes.

Is Arm’s Length Range a Concept or Reality under Transfer Pricing

October 3, 2022 2286 Views 0 comment Print

The arm’s length range is an everchanging range as different transfer pricing methods yield a different range of figures which may all be workable. With regard to this, the arm’s length principle can only generate a comparison of the set of conditions that would have been approved between independent enterprises.

Preserving and Applicability of Arm’s Length Principle

September 14, 2022 1383 Views 0 comment Print

While it may not be perfect, the member countries of the OECD focus have a tendency that the arm’s length principle should govern the judgment of transfer pricing between associated enterprises.

Pricing Methods to detect Related Parties’ Transactions

August 30, 2022 2538 Views 0 comment Print

Discover the significance of pricing methods in detecting related party transactions. Learn how multinational companies reduce tax liabilities through progressive pricing.

Organization for Economic Cooperation and Development (OECD)

August 27, 2022 1305 Views 0 comment Print

Understanding the role of the Organization for Economic Cooperation and Development (OECD) in international taxation and transfer pricing.

Separate Corporate Personality

July 8, 2020 6804 Views 1 comment Print

A company once registered, has a legal personality. Corporate groups are identified as a legal individual/body/entity, independent from the group’s directors and shareholders. Ergo the officers, directors or shareholder can act on behalf of the legal body without any liability as it remains with the entity.

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