Income Tax : Explore the concept of transaction recharacterization in transfer pricing. Understand its rationale, benefits, and challenges in g...
Income Tax : Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023....
Income Tax : India's Transfer Pricing regulations for FY 2023-24 (AY 2024-25) - This detailed chart lists key activities, legal sections, requi...
CA, CS, CMA : Learn about transfer pricing, its importance, methods, documentation, penalties for non-compliance, and advanced pricing agreement...
Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...
Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...
Income Tax : What is the procedure to approve Form 3CEB? Form uploaded by CA shall be available under For your action tab in Taxpayer’s Workl...
Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...
Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...
Income Tax : Voice Of CA has made a Request for Extension of specified date of filing Tax Audit Report and other forms falling due on or before...
Income Tax : ITAT Hyderabad directed to exclude companies having turnover of more than or less than 10 times of the turnover of the assessee fr...
Income Tax : ITAT Mumbai held that no transfer pricing adjustment could have been made in the hands of assessee on account of ALP of specified ...
Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...
Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...
Income Tax : ITAT Delhi rules RPM as the best method for benchmarking solar goods purchases in the D Light Energy P. Ltd. vs Assessing Officer ...
Income Tax : Stay informed on the latest Income Tax Rule changes with Notification No. 104/2023 by the Ministry of Finance. Learn about amendme...
Income Tax : Read how CBDT's Notification No. 58/2023 amends Income-tax Rules, extending Safe Harbour rules to AY 2023-24. Insights from Minist...
Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
Income Tax : In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act, 1961 (43 of 1961...
Income Tax : Safe Harbour rules for AY 2022 2023 | Income tax Act, 1961 | Notification No. 66/2022-Income-Tax | Dated: 17th June, 2022 | CBDT...
ITAT Delhi held that deriving Arm’s Length Price without resorting to any method prescribed as per the Income Tax Rules is unjustifiable. Accordingly, TPO/ AO directed to determine Arm’s Length Price.
ITAT Delhi held that when the transaction between the assessee and its Indian AE is found to be at arm’s length, no further attribution of profit can be made to the dependent agent PE in India.
Calcutta High Court held that mere usage of foreign word does not make it automatic to fall within the ambit of an international transaction.
Philips India Ltd. vs ACIT (ITAT Kolkata) In many cases, licensed manufacturers operate as risk-bearing entrepreneurs, and there is no existence of an ‘agreement’ or ‘arrangement’ or ‘understanding’ with the AE regarding AMP expenditure, the initial onus is on the revenue to show that there is an international transaction for AMP spend. The mere fact […]
ITAT Ahmedabad held that arms length interest rate for loan advanced to foreign subsidiary by Indian company should be computed based on market determined interest rate applicable to currency in which loan has to be repaid.
Learn why the TNM method may not be suitable for determining the Arms Length Price (ALP) in capital goods purchase transactions under transfer pricing regulations in India. Understand the legal perspectives and recent case decisions.
Understand the differences between the UN and OECD Model Tax Conventions and their application in Indian tax treaties. Dive into article-by-article comparisons and India’s unique tax treaty policies.
Understand the intricacies of Transfer Pricing regulations in the UAE with an overview of the CT Law, including the Arm’s Length Principle, Related Parties, Payments to Connected Persons, and Transfer Pricing Documentation requirements.
OECD/G20 Inclusive Framework (IF) on BEPS released technical guidance to assist governments with implementation of the GMT, which will ensure Multi-National Entities (MNEs) will be subject to a 15% effective minimum tax rate.
Section 92C(1) of Act, contemplates that arms length price in relation to an international transaction shall be determined by comparable uncontrolled price method; resale price method; cost plus method; profit split method; transactional net margin method or such other method as may be prescribed by Board.
