OECD articles

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...

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Posted Under: Income Tax |

Analyzing draft rules notified on Country-by-Country Reporting (CbCR)

As a measure of safeguard against base erosion and profit shifting (BEPS) by Multinational Enterprises (MNEs) and following the Action Plan 13 of OECD, of which the India is a member country, the amendment was made recently in the Income Tax Act mandating the maintenance and furnishing of Master File and filing of Country-by-Country Repor...

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Posted Under: Income Tax |

Thin capitalisation – impact on future debt raising

The taxation regime in India seems to be undergoing crucial changes to negate the above quote from one of the greatest philosophers of all times. On this backdrop, the principles of thin capitalisation as prescribed in the Organization for Economic Cooperation and Development (‘OECD’) Base Erosion and Profit Shifting (‘BEPS) Action ...

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Posted Under: Income Tax |

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....

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Posted Under: Income Tax |

Transfer Pricing Documentation: Convergence with BEPS Action Plan

OECD stands for Organization for Economic Co-operation and Development. It is an international organization comprising of 34 countries with an objective to stimulate economic progress and world trade. The organization actively conducts researches in various areas of taxation and economic development based on which it issues recommendation...

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Posted Under: Income Tax |

Latvia invited to join OECD and Related FAqs

11/5/2016 – OECD countries agreed today to invite Latvia to become a member of the Organisation – a move that would extend OECD’s membership to 35 countries. OECD Secretary-General, Angel Gurría Said: “We are very pleased to welcome Latvia as a member of the OECD. This development reaffirms our Organisation’s commitment to...

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Posted Under: Income Tax |

BEPS and India Budget 2016 Proposals

The objective of the BEPS Project is to close gaps in international tax rules, effectively eliminating or substantially reducing BEPS; and to secure government revenues by ensuring that profits are taxed in the jurisdiction where the economic activities generating such profits are performed and where value is created....

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Posted Under: Income Tax |

Equalization levy or is it introduction of tax on DIGITAL ECONOMY

Action plan on Base Erosion and Profit Shifting (‘BEPS’) issued by Organization for Economic Co-Operation and Development’s (‘OECD’) inter alia has proposed to levy a tax on digital transaction to equalize the tax burden on remote and domestic supplier of goods as well as services....

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Posted Under: Income Tax |

GAAR or BEPS, What would be India’s right choice?

General Anti Avoidance Rule (GAAR) v. Base Erosion & Profit Shifting (BEPS) or both: what is India’s right choice? With India’s commitment to implement most of the recommendations of the final reports of Organization for Economic Cooperation and Development’ (OECD) BEPS Action Plans, and at the same time ensure simplification as...

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Posted Under: Income Tax |

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