OECD

Thin Capitalisation introduced under Income-tax with FAQs

Income Tax - In order to curb structuring by the multinational group Companies having their presence through subsidiaries/ associate companies or permanent establishments in India, the Finance Act 2017 introduced a new section 94B under the Income-tax Act, 1961 (the Act), in line with the recommendations of OECD BEPS Action Plan 4...

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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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Domestic Dependent Agency Rules – Parity with MLI standards

Income Tax - 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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Scope of “business connection” with modified PE Rule as per MLI

Income Tax - The OECD under BEPS Action Plan 7 reviewed the definition of 'PE' with a view to preventing avoidance of payment of tax by circumventing the existing PE definition by way of commissionaire arrangements or fragmentation of business activities. ...

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Transfer Pricing Documentation and Reporting

Income Tax - This article analyses the provisions notified to give effect to the OECD recommendations on three tiered Transfer Pricing documentation, regarding the entities to which the provisions will apply....

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Acceptance of Transfer Pricing MAP and bilateral APA – Reg.

Income Tax - Clarification of India’s position on the acceptance of MAP and bilateral APA in cases of countries where Article 9(2) of OECD Model Tax Commentary is absent...

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Fighting Tax Crime: The Ten Global Principles

Income Tax - This report sets out the 10 essential principles for effectively fighting tax crimes. It covers the legal, institutional, administrative, and operational aspects necessary for putting in place an efficient system for fighting tax crimes and other financial crimes. It draws on the insights and experience of jurisdictions around the world. ...

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Effective Inter-Agency Co-Operation in Fighting Tax Crimes and Other Financial Crimes (Third Edition)

Income Tax - This report describes the current position in 51 countries as to the law and practice for domestic inter-agency co-operation in fighting tax crimes and other financial crimes including, for the first time, co-operation with authorities responsible for the investigation and prosecution of corruption. It identifies successful practices base...

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Tax Inspectors Without Borders – Bolstering domestic revenue collection through improved tax audit capacities

Income Tax - International tax experts gathered today at the OECD in Paris to share experiences and identify best practices in the implementation of Tax Inspectors Without Borders (TIWB) programmes....

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OECD updates transfer pricing country profiles reflecting transfer pricing legislation and practices

Income Tax - The OECD has published updated versions of transfer pricing country profiles (TPCP), reflecting the current transfer pricing legislation and practices of 31 participating countries. The country profiles contain up-to-date and harmonised information on key aspects of transfer pricing legislation, provided by countries themselves....

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ITAT – taking virtual reality a bit too seriously ?

ABB FZ - LLC, Bangalore Vs. Dy.DIT, Bangalore (ITAT Bangalore) - A reader should be able to come to his / her own conclusion by applying the legislative enactments and judicial pronouncements to the facts of the case. While re-producing any portion of legislative enactment or judicial pronouncement, it is para phrased and emphasis is supplied by way of underline....

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No bar Under OECD to provide document relied to Appellant; Mere showing of document not sufficient

Poonam Jain Vs Union of India & Ors. (Delhi High Court) - High Court held that to say that the person being prosecuted or proceeded against can only be 'shown' such documents, but not provided copies thereof is untenable even on a plain reading of Article 26 (2) of the OECD Model Convention....

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SEBI Meeting on Implementation of OECD Principles of Corporate Governance, Spot Price Determination of Commodities etc.

PR No. 297/2015 - (23/12/2015) - PR No. 297/2015 Sixth Meeting of the International Advisory Board of SEBI The Sixth meeting of the International Advisory Board (IAB) of the Securities and Exchange Board of India (SEBI) was held on December 21 & 22, 2015. The following major issues were inter alia discussed during the meeting: ...

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Guidance on Implementation on FATCA and CRS

F. No. 500/137/2011-FTTR-III - (31/08/2015) - To combat the problem of offshore tax evasion and avoidance and stashing of unaccounted money abroad requiring cooperation amongst tax authorities, the G20 and OECD countries working together developed a Common Reporting Standard (CRS) on Automatic Exchange of Information (AEOI). The CRS on AEOI was...

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Recent Posts in "OECD"

Thin Capitalisation introduced under Income-tax with FAQs

In order to curb structuring by the multinational group Companies having their presence through subsidiaries/ associate companies or permanent establishments in India, the Finance Act 2017 introduced a new section 94B under the Income-tax Act, 1961 (the Act), in line with the recommendations of OECD BEPS Action Plan 4...

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 |

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...

Read More
Posted Under: Income Tax |

Scope of “business connection” with modified PE Rule as per MLI

The OECD under BEPS Action Plan 7 reviewed the definition of 'PE' with a view to preventing avoidance of payment of tax by circumventing the existing PE definition by way of commissionaire arrangements or fragmentation of business activities. ...

Read More
Posted Under: Income Tax |

Transfer Pricing Documentation and Reporting

This article analyses the provisions notified to give effect to the OECD recommendations on three tiered Transfer Pricing documentation, regarding the entities to which the provisions will apply....

Read More
Posted Under: Income Tax |

Transfer pricing guidelines– Global/Indian scene: Latest income tax obligations of entities

The following article has been written to explain the salient features of the reporting requirements enforced on corporations in India/abroad which are said to assist tax authorities around the world to use transfer pricing audit to get the tax due to their countries from corporations who seemed to have found various ways to avoid the tax...

Read More
Posted Under: Income Tax |

Acceptance of Transfer Pricing MAP and bilateral APA – Reg.

Clarification of India’s position on the acceptance of MAP and bilateral APA in cases of countries where Article 9(2) of OECD Model Tax Commentary is absent...

Read More
Posted Under: Income Tax |

Fighting Tax Crime: The Ten Global Principles

This report sets out the 10 essential principles for effectively fighting tax crimes. It covers the legal, institutional, administrative, and operational aspects necessary for putting in place an efficient system for fighting tax crimes and other financial crimes. It draws on the insights and experience of jurisdictions around the world. ...

Read More
Posted Under: Income Tax |

Effective Inter-Agency Co-Operation in Fighting Tax Crimes and Other Financial Crimes (Third Edition)

This report describes the current position in 51 countries as to the law and practice for domestic inter-agency co-operation in fighting tax crimes and other financial crimes including, for the first time, co-operation with authorities responsible for the investigation and prosecution of corruption. It identifies successful practices base...

Read More
Posted Under: Income Tax |

Tax Inspectors Without Borders – Bolstering domestic revenue collection through improved tax audit capacities

International tax experts gathered today at the OECD in Paris to share experiences and identify best practices in the implementation of Tax Inspectors Without Borders (TIWB) programmes....

Read More
Posted Under: Income Tax |
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