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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...
Read MoreIncome 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...
Read MoreIncome 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. ...
Read MoreIncome 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. ...
Read MoreIncome 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....
Read MoreIncome 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....
Read MoreIncome 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. ...
Read MoreIncome 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....
Read MoreIncome Tax - Finance Act, 2012 extended the obligation to withhold taxes to non- residents irrespective of whether the non-resident has -...
Read MoreIncome 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...
Read MoreM/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....
Read MoreDIT 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...
Read MoreCarpi 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....
Read MoreTally 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. ...
Read MoreDCIT 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...
Read MoreNotification 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...
Read MoreNotification 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,-...
Read MoreCircular 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...
Read MoreF 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...
Read MoreCircular 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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