international taxation

Rule 10DA – Requirements for filing a Master File

Income Tax - The Central Board of Direct Taxes (CBDT), has released the final rules through a notification (N No. 3497(E) on preparation and filing of Master file by the Indian Entity of an International group. The brief of the rules as notified and the documentation/information requirements as needed for the filing are summarized herewith for your re...

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Budget 2018: Impact Analysis of Country by Country Reporting

Income Tax - It was proposed in Finance Act 2016. It is a part of three-tiered transfer pricing documentation structure which must be maintained and produced before the income-tax authorities along with a master file (contains standardized information relevant for all Multinational enterprise group members) and a local file (refers specifically to mat...

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Union Budget 2018: Streamlining Business Connection in accordance with BEPS Action Plan

Income Tax - It has been widely reported that multinational corporations resort to base erosion and profit sharing (BEPS) techniques to shift their profit to tax havens or nations with lower tax incidence. ...

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Country by Country Reporting (CbC Reporting) – India’s Step Forward to OECD’s BEPS Action Plans

Income Tax - The OECD report on Action Plan 13 of BEPS Action plan provides for re-examination of transfer pricing documentation. It also provides for a template for country-by-country reporting of income, earnings, taxes paid and certain measure of economic activity. ...

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Business Connection – A modified Permanent Establishment Rule!

Income Tax - India, amongst various countries, participated in the signing of the Multilateral Instrument (MLI) on 7 June 2017, to implement tax treaty related measures as a part of the various Base Erosion and Profit Shifting (BEPS) related Action Plans....

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India and Kazakhstan sign Protocol to amend DTAC

Income Tax - The Protocol provides internationally accepted standards for effective exchange of information on tax matters. Further, the information received from Kazakhstan for tax purposes can be shared with other law enforcement agencies with the authorisation of the competent authority of Kazakhstan and vice versa....

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Govt clarifies on requirement of furnishing Country-by Country Report

Income Tax - The Government of India issues clarification regarding requirement for furnishing of Country-by Country Report under Section 286(4) of Income Tax Act, 1961. ...

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ICRICT new paper: “A Roadmap to improve rules for taxing multinationals”

Income Tax - ICRICT is launching today a new publication presenting concrete solutions to reorient the existing system of international taxation away from serving the wealthy few and to focus it instead on addressing the needs of the vast majority of the population....

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Section 195: 6 Suggestions made by ICAI for Rationalization of Provisions

Income Tax - Finance Act, 2012 extended the obligation to withhold taxes to non- residents irrespective of whether the non-resident has -...

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Reporting of U.S. TINs for pre-existing accounts by Financial Institutions

Income Tax - India and USA have signed the Inter-Governmental Agreement (IGA) under FATCA in 2015. To enhance the effectiveness of information exchange and transparency, both the sides committed to establish, by January 1, 2017, rules requiring their Reporting Financial Institutions (RFIs) to obtain the Tax Identity Number (TIN) of each report able pe...

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TDS deductible on Remittance to Google Ireland by Google India

M/s. Google India Private Ltd. Vs. Addl. Commissioner of Income-tax (ITAT Bangalore) - A division bench of the Bengaluru ITAT, on Tuesday held that the distribution fee paid by Google India to Google Ireland for use of its Ad words programme is taxable in India as royalty under the provisions of the Income Tax Act, 1961....

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Payment for Net Communication system developed by principal for smooth functioning of shipping business is not FTS

DIT Vs. A. P. Moller Maersk, (Supreme Court) - In this Case Hon’ble Supreme Court held that Payments made by the agents to the concerned foreign assessee, for using the facility of Net Communication System, developed by the assessee for smooth functioning of its international shipping business cannot be classified as fees for technical ser...

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Taxability of business done by NRI through Power of Attorney holder

Carpi Tech SA Vs ADIT (ITAT Chennai) - Assessee submitted that project receipt from Tanakpur Power Project of NHPC work is exempt from tax in India for the reason that assessee does not have continuous presence or 'business connection' or a permanent establishment in India....

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TP – Notional Interest on Excess Credit Period/ Delayed Payment

Tally Solutions Pvt. Ltd. Vs. ACIT (ITAT Bangalore) - The treatment of extended credit period to Associated Enterprises(AEs) as an international transaction and making adjustment of notional interest on the same has always been bone of contention between the assessee and department. ...

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TDS not deductible on web hosting & marketing services procured from US based entity

DCIT Vs M/s Matrimony.Com Pvt. Ltd. (ITAT Chennai) - The ITAT Chennai held that payments made by the assessee in the nature of webhosting and marketing expenses to US based service provider could not be taxed as Fees for technology services because there were not transfer of technology involved in render of services such that the services could be con...

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India notifies provisions of DTAA/ Protocol entered with New Zealand

Notification No. 93/2017-Income Tax - (02/11/2017) - Agreement between the Government of the Republic of India and the Government of the Government of New Zealand for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes - Notification No. 93/2017 - Income Tax...

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CBDT notifies rules for Country-By-Country Report and Master File rules

Notification No. 92/2017 / S.O. 3497(E) - (31/10/2017) - Information and documents to be kept and maintained under proviso to sub-section (I) of section 92D and to be furnished in terms of sub-section (4) of section 92D. 10DA. (1) Every person, being a constituent entity of an international group shall,-...

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CBDT extends due date for filing of Country-by-Country Report for 2016-17 to 31.03.2018

Circular No. 26/2017-Income Tax - (25/10/2017) - Circular No. 26/2017 : Order under section 119 of the Income-tax Act, 1961 in respect of extension of due date for filing of Country-by-Country Report for reporting accounting year 2016-17...

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Draft Notification on foreign company resident in India U/s. 115JH

F No 370142/19/2017-TPL - (15/06/2017) - CBDT invites comments and suggestions on the Draft Notification in respect of foreign company said to be resident in India under Section 115JH of the Income-tax Act, 1961...

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Reg. removal of Cyprus from list of notified jurisdictional areas U/s. 94A

Circular No. 15/2017-Income Tax - (21/03/2017) - It is hereby clarified that Notification No. 86/2013 has been rescinded with effect from the date of issue of the said notification, thereby, removing Cyprus as a notified jurisdictional area with retrospective effect from 01.11.2013....

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Recent Posts in "international taxation"

India and Kazakhstan sign Protocol to amend DTAC

The Protocol provides internationally accepted standards for effective exchange of information on tax matters. Further, the information received from Kazakhstan for tax purposes can be shared with other law enforcement agencies with the authorisation of the competent authority of Kazakhstan and vice versa....

Read More
Posted Under: Income Tax |

Govt clarifies on requirement of furnishing Country-by Country Report

The Government of India issues clarification regarding requirement for furnishing of Country-by Country Report under Section 286(4) of Income Tax Act, 1961. ...

Read More
Posted Under: Income Tax |

Rule 10DA – Requirements for filing a Master File

The Central Board of Direct Taxes (CBDT), has released the final rules through a notification (N No. 3497(E) on preparation and filing of Master file by the Indian Entity of an International group. The brief of the rules as notified and the documentation/information requirements as needed for the filing are summarized herewith for your re...

Read More
Posted Under: Income Tax |

Budget 2018: Impact Analysis of Country by Country Reporting

It was proposed in Finance Act 2016. It is a part of three-tiered transfer pricing documentation structure which must be maintained and produced before the income-tax authorities along with a master file (contains standardized information relevant for all Multinational enterprise group members) and a local file (refers specifically to mat...

Read More
Posted Under: Income Tax |

Union Budget 2018: Streamlining Business Connection in accordance with BEPS Action Plan

It has been widely reported that multinational corporations resort to base erosion and profit sharing (BEPS) techniques to shift their profit to tax havens or nations with lower tax incidence. ...

Read More
Posted Under: Income Tax |

Country by Country Reporting (CbC Reporting) – India’s Step Forward to OECD’s BEPS Action Plans

The OECD report on Action Plan 13 of BEPS Action plan provides for re-examination of transfer pricing documentation. It also provides for a template for country-by-country reporting of income, earnings, taxes paid and certain measure of economic activity. ...

Read More
Posted Under: Income Tax |

Business Connection – A modified Permanent Establishment Rule!

India, amongst various countries, participated in the signing of the Multilateral Instrument (MLI) on 7 June 2017, to implement tax treaty related measures as a part of the various Base Erosion and Profit Shifting (BEPS) related Action Plans....

Read More
Posted Under: Income Tax |

ICRICT new paper: “A Roadmap to improve rules for taxing multinationals”

ICRICT is launching today a new publication presenting concrete solutions to reorient the existing system of international taxation away from serving the wealthy few and to focus it instead on addressing the needs of the vast majority of the population....

Read More
Posted Under: Income Tax |

U S Taxation – With April 18, 2018 filing deadline, taxation season starts: Latest instructions

With snow reportedly falling in Philadelphia, USA and other places, Internal Revenue Service(IRS), the most dynamic tax collecting wing of the Federal Government of USA, opened the electronic filing window on January 29, 2018, enabling millions of tax payers to start the process of tax filing and aspire for tax refunds, if eligible. ...

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Posted Under: Income Tax |

Domestic Dependent Agency Rules – Parity with MLI standards

The concept of Business connection under the domestic tax laws is akin to concept of PE in international parlance. The term ‘business connection’ includes activities carried on by non-resident through its dependent agents. Presently, a person acting on the behalf of the non-resident by negotiating and concluding contracts, maintaining...

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Posted Under: Income Tax |
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