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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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...
When the transaction of purchase of shares are held to be outside the purview of the provisions of Sec.92 of the Act, we fail to understand as to how the excess price paid for acquiring shares can be treated as a deemed loan and an international transaction. We therefore find no merits in the argument advanced by the learned DR.
The Goods and Services Tax (GST) is being introduced in the country after 13 year long journey since it was first discussed in report by Kelkar Task Force on indirect taxes. Agreeably, one could count GST as country’s biggest tax reform which can trigger transformation on how businesses works across all industries and overhaul India’s […]
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. The purpose is to allow […]
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 based on countries’ experiences of inter-agency co-operation in […]
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.
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.
The Central Board of Direct Taxes (CBDT), on 31st October, 2017, has notified the final set of Rules for Maintaining and Furnishing of Transfer Pricing Documentation under Income Tax Rules 1962. Objective: To introduce provisions for additional TP documentation and Country – by – Country reporting to implement the recommendations contained in the Organization for Economic Co-operation and Development (OECD)’s BEPS report on Action 13 The Draft Rules were issued on 6th October 2017 and kept open until 16th October 2017 for public & stakeholders comments and suggestions, if any, by electronically.
After the recent worldwide implementation of OECD’s recommendations to prevent Base Erosion and Profit Shifting (BEPS), another forum (The Platform for Collaboration on Tax) has released a discussion draft on The Taxation of Offshore Indirect Transfers – A toolkit (hereafter, referred as the toolkit) for public comments on 1 August, 2017.
The salient features of the Country-By-Country Report and Master File rules are as under: The threshold for the Country-By-Country Report is total consolidated group revenue of Rs. 5,500 crore or more.
Information and documents to be kept and maintained under proviso to sub-section (I) of section 92D and to be furnished in terms of sub-section (4) of section 92D. 10DA. (1) Every person, being a constituent entity of an international group shall,-
