international transactions

Understanding Double Taxation and Relief Mechanisms

Income Tax - Uncover the concept of Double Taxation, its types - Juridical and Economic, and learn about relief mechanisms such as Unilateral and Bilateral relief....

Transfer Pricing- Corporate Guarantee as an International Transaction

Income Tax - In Transfer pricing proceedings, corporate guarantee given by assessee to its foreign AE is always disputed by the department as an international transaction and adjustment determined on the basis of average bank guarantee rates. However, in number of judgements by tribunal and HC, the stand of the department is overruled and relief grant...

Insider trading in USA: Its evolution, current rules and other titbits

Income Tax - Insider trading, the bane of many Indians who were caught and jailed for their infamous acts is not new to USA. Even in 1700s, Mr. Nilliam Duer, Assistant Secretary, Treasury Department of Federal Government, USA, used his position to guide the purchase of bonds. This article intends to guide its evolution, current rules and show [&hellip...

Complete NRI Guide to Property in India

Income Tax - This article attempts to dispel the doubts in the minds of such prospective NRI investors by addressing key issues pertaining to property dealings in India....

US Taxation– Form 1040– Foreign earned income & foreign tax credit

Income Tax - For a U S citizen or a resident alien, the US tax authorities are happy to get them paid the taxes even on their income earned abroad. The case goes back to 1930s when US companies started earning exports in France and UK particularly raising queries on adopting transfer pricing policies. ...

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...

CBDT in a fix over the application of one safe harbour rate to all sectors

Income Tax - The Central Board of Direct Taxes (CBDT) is in a fix over the application of one safe harbour rate to all sectors. A committee, formed last month to frame safe harbour rules as announced in the 2009-10 Budget to minimise transfer pricing disputes, has estimated that there is a huge difference in the margins of companies which would come u...

ICAI Announced – e-Learning course on Transfer Pricing

Income Tax - The Finance Act, 2001 has introduced Sections 92 to 92F in the Income-Tax Act, 1961 with effect from Assessment Year 2002-2003 and these provisions are commonly referred to as transfer pricing regulations. These provisions deal with the methods of computation of income from international transactions, the document to be maintained by the ...

Importance of Section 90(1) Notification in DTAA: SC’s Ruling

Assessing Officer Circle (International Taxation) Vs Nestle SA (Supreme Court) - Learn why a Section 90(1) notification is crucial for a DTAA's enforcement, as per the Supreme Court's landmark judgment in AO vs. Nestle SA. Understand its impact and implications....

Counter guarantee with negligible risks cannot be compared with guarantee with high risk 

MUFG Bank Ltd. Vs ACIT (ITAT Delhi) - ITAT Delhi held that adoption of Comparable Uncontrolled Price (CUP) method for determining Arm’s Length Price (ALP) of the international transaction is unjustified....

Amount received in the nature of interest is taxable @15% under Article 12 of India-UK DTAA

Karnail Singh Vs ADIT (ITAT Chandigarh) - ITAT Chandigarh held that the amount of monthly assured return received till the time of possession of units is in nature of interest is taxable @15% under Article 12 of India-UK DTAA...

AMP expense can’t be disallowed, Merely because Excess amount has been spent on Advertisement

Gillatte India Ltd. Vs ACIT (ITAT Jaipur) - Whether the TPO was legally justified in holding that AMP expenditure was not an international transaction even though the assessee was performing DEMPE functions for its AE and doing activity of brand building?...

No section 92CA(3) Adjustment for Corporate Guarantees

DCIT Vs Gujarat NRE Coke Ltd (ITAT Kolkata) - The issue under consideration is whether the deletion of adjustment made u/s 92CA(3) of the Act on account of interest on loan and on account of corporate guarantees is justified in law?...

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Recent Posts in "international transactions"

Importance of Section 90(1) Notification in DTAA: SC’s Ruling

Assessing Officer Circle (International Taxation) Vs Nestle SA (Supreme Court)

Learn why a Section 90(1) notification is crucial for a DTAA's enforcement, as per the Supreme Court's landmark judgment in AO vs. Nestle SA. Understand its impact and implications....

Understanding Double Taxation and Relief Mechanisms

Uncover the concept of Double Taxation, its types - Juridical and Economic, and learn about relief mechanisms such as Unilateral and Bilateral relief....

Posted Under: Income Tax |

Counter guarantee with negligible risks cannot be compared with guarantee with high risk 

MUFG Bank Ltd. Vs ACIT (ITAT Delhi)

ITAT Delhi held that adoption of Comparable Uncontrolled Price (CUP) method for determining Arm’s Length Price (ALP) of the international transaction is unjustified....

Amount received in the nature of interest is taxable @15% under Article 12 of India-UK DTAA

Karnail Singh Vs ADIT (ITAT Chandigarh)

ITAT Chandigarh held that the amount of monthly assured return received till the time of possession of units is in nature of interest is taxable @15% under Article 12 of India-UK DTAA...

Transfer Pricing- Corporate Guarantee as an International Transaction

In Transfer pricing proceedings, corporate guarantee given by assessee to its foreign AE is always disputed by the department as an international transaction and adjustment determined on the basis of average bank guarantee rates. However, in number of judgements by tribunal and HC, the stand of the department is overruled and relief grant...

Posted Under: Income Tax |

AMP expense can’t be disallowed, Merely because Excess amount has been spent on Advertisement

Gillatte India Ltd. Vs ACIT (ITAT Jaipur)

Whether the TPO was legally justified in holding that AMP expenditure was not an international transaction even though the assessee was performing DEMPE functions for its AE and doing activity of brand building?...

Insider trading in USA: Its evolution, current rules and other titbits

Insider trading, the bane of many Indians who were caught and jailed for their infamous acts is not new to USA. Even in 1700s, Mr. Nilliam Duer, Assistant Secretary, Treasury Department of Federal Government, USA, used his position to guide the purchase of bonds. This article intends to guide its evolution, current rules and show [&hellip...

Posted Under: Income Tax |

No section 92CA(3) Adjustment for Corporate Guarantees

DCIT Vs Gujarat NRE Coke Ltd (ITAT Kolkata)

The issue under consideration is whether the deletion of adjustment made u/s 92CA(3) of the Act on account of interest on loan and on account of corporate guarantees is justified in law?...

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

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...

Posted Under: Income Tax |

Complete NRI Guide to Property in India

This article attempts to dispel the doubts in the minds of such prospective NRI investors by addressing key issues pertaining to property dealings in India....

Posted Under: Income Tax |

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