international transactions

Complete NRI Guide to Property in India

Finance - 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....

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

Finance - 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. ...

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Transfer Pricing- Aggregation of Transactions for Benchmarking

Finance - Aggregation of transactions or ‘Combined Transaction Approach’ is a well-accepted practice for benchmarking and determination of Arms’ Length Price of international transaction/ specified domestic transactions in Transfer Pricing Certification and assessments and is widely upheld in many judgements....

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Transfer Pricing- Corporate Guarantee as an International Transaction

Finance - 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...

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Rules for Grant of Foreign Tax Credit in India

Finance - CBDT has, vide Notification no. 54/2016 dated 27th June 2016, notified Rules for grant of Foreign Tax Credit (FTC). The said rules are applicable from Assessment Year 2017-18 onwards. Earlier, the CBDT had released draft FTC rules on 18th April 2016 for public comments and on the basis of comments received, the final rules are notified....

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

Finance - 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...

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ICAI Announced – e-Learning course on Transfer Pricing

Finance - 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 ...

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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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If there is International transaction, Arm’s Length Price would be decided using international commercial principle.

CIT Vs M/s Cotton Naturals (I) Pvt. Ltd. (Delhi High Court) - Assessee had given the loan to the associate enterprise in U.S.D. and in such a situation when the transaction was in foreign currency, and the transaction was an international transactions, then the transaction would have to be looked upon by applying the commercial principles in regard to internat...

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Outstanding receivables from international transactions held to be within the jurisdiction of TPO

Logix Micro Systems Ltd. Vs. ACIT (ITAT Bangalore) - By considering the potential loss on the long standing receivables as a genuine adjustment in the course of assessment, the Tribunal has reinforced the principles that the concept of TP cannot be that of an exact science and that constant application...

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Use of Cash Profit / Sales and Cash Profit / Cost emphasized as an appropriate PLI for use of TNMM

Schefenacker Mother son Ltd Vs. ITO and Schefenacker Mother son Ltd Vs. DCIT [ITAT Delhi] - In the case of Schefenacker Motherson Ltd v. ITO, ITA No. 4459/DEL/07 for AY 2003-04 and schefenacker Motherson Ltd v. DCIT, ITA No.4460/DEL/07 for AY 2004-05, the Delhi Bench of the Income-tax Appellate Tribunal (the Tribunal), held that cash profit on sales “CP/Sales” or cash profit on total ...

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AAR on tax liability of a partnership firm to be formed in Canada by a Canadian company for executing its PSCs in India

Canoro Resources Limited, In re (Authority for Advance Rulings-Income Tax) - 10.1 It is the common stand of both - the applicant and the Revenue, that the nature of income arising from the transfer of the applicant's participating interest in Amguri block to the proposed partnership firm, shall be capital gains. Where they differ is regarding the mode of computation of that ...

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Recent Posts in "international transactions"

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....

Read More
Posted Under: Finance |

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

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. ...

Read More
Posted Under: Finance |

Transfer Pricing- Aggregation of Transactions for Benchmarking

Aggregation of transactions or ‘Combined Transaction Approach’ is a well-accepted practice for benchmarking and determination of Arms’ Length Price of international transaction/ specified domestic transactions in Transfer Pricing Certification and assessments and is widely upheld in many judgements....

Read More
Posted Under: Finance |

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...

Read More
Posted Under: Finance |

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. ...

Read More

Rules for Grant of Foreign Tax Credit in India

CBDT has, vide Notification no. 54/2016 dated 27th June 2016, notified Rules for grant of Foreign Tax Credit (FTC). The said rules are applicable from Assessment Year 2017-18 onwards. Earlier, the CBDT had released draft FTC rules on 18th April 2016 for public comments and on the basis of comments received, the final rules are notified....

Read More
Posted Under: Finance |

Guiding Principles For Determination of POEM of a Company

In order to curb the erstwhile lacuna in the language of the Act and to prevent formations of various foreign shell companies, which are eventually controlled and managed from India, the Government of India amended the provision of clause (ii) of sub-section 3 of section 6 of the Act vide Finance Act, 2015 to avoid future revenue losses a...

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Posted Under: Finance |

If there is International transaction, Arm’s Length Price would be decided using international commercial principle.

CIT Vs M/s Cotton Naturals (I) Pvt. Ltd. (Delhi High Court)

Assessee had given the loan to the associate enterprise in U.S.D. and in such a situation when the transaction was in foreign currency, and the transaction was an international transactions, then the transaction would have to be looked upon by applying the commercial principles in regard to international transactions....

Read More

Explanation 5 to Section 9(1)(i) – “Substantial” clarity by Delhi HC

Explanation 5 to section 9(1)(i) of the Income-tax Act, 1961 (“the Act”) introduced by the Finance Act 2012 is no longer res integra in view of the pronouncement by the Delhi High Court. In its recent judgement in the case of DIT vs. Copal Research Limited And Ors.: W.P. 2033/2013, the Delhi High Court has held that gains arising from...

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Posted Under: Finance |

International Transaction or Cross Border Transactions

An International Transaction or Cross Border Transaction can be defined as a transaction in an international trade between two or more entities beyond the territorial limits of a country or a transaction in a domestic trade in which at least one of the party is located outside the country of the transaction....

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Posted Under: Finance |
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