Wednesday , December 13, 2017 |   12:42:37 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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NEWS FLASH
 
TP - Amortization of software expenses and forex loss are required to be excluded, while working out operating profit of assessee from export of goods to its AE: ITAT (See 'Breaking News') TP - DRP cannot reject comparables merely because TPO had no occasion to consider them in TP proceedings, if their functional profile & financial parameters are not disputed: ITAT (See 'Breaking News') DTAA - Profits attributable to India’s operation cannot be assessed as 'business profits' in absence of PE, merely because foreign company had business connection in India: ITAT (See 'Breaking News') I-T - When Protocol to treaty itself provides for automatic application of amended provisions of treaty, even then Revenue can insist on separate notification to be issued by Central Govt about beneficial provisions of treaty - HC (See 'Breaking News') CRS Disclosure - OECD seeks inputs on Model Disclosure Rules ( See 'Brief') TP - Transfer pricing matter deserves re adjudication, if information furnished before TPO is incomplete, since Assessee was not granted opportunity to submit the same: ITAT (See 'Breaking News') TP - No ALP adjustment can be made on protective basis applying the bright line test, in case of transaction of AMP expenses: ITAT (See 'Breaking News') DTAA - There is no obligation to deduct TDS on professional charges paid to Non resident, if such payment did not fall within definition of royalty either under DTAA or I-T Act: ITAT (See 'Breaking News') I-T - Assessee should be allowed to withdraw its appeal in view of MAP resolution as agreed between Competent Authorities of India & Foreign State: ITAT (See 'Breaking News') TP - Disagreement over application of benchmarking method, would not amount to question of law, unless it is established that such application resulted in distorted outcome: HC (See 'Breaking News') TP - Royalty paid by AEs to their parent group company, cannot be treated as capital expenditure: ITAT (See 'Breaking News') DTAA - Global corporate guarantee agreement entered with NRI company for securing loans to AEs, cannot be treated as business profit: ITAT (See 'Breaking News') I-T - Mere failure to record detailed discussion in consequential order, is not sufficient to hold that AO has decided to allow expenditure without verification: ITAT (See 'Breaking News') TP - Rate of interest in case of pending receivables from AEs should be determined by applying LIBOR plus suitable basis point keeping in view credit score of AEs: ITAT (See 'Breaking News') TP - When determination of ALP in appeal effect order did not lead to any TP adjustment, with no effect on income of Assessee, no penalty provisions is applicable in such case: ITAT (See 'Breaking News')
 
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TII BREAKING NEWS
 
TP - Amortization of software expenses and forex loss are required to be excluded, while working out operating profit of assessee from export of goods
TP - DRP cannot reject comparables merely because TPO had no occasion to consider them in TP proceedings, if their functional profile & financial parameters
DTAA - Profits attributable to India’s operation cannot be assessed as 'business profits' in absence of PE, merely because foreign company had business connection in
I-T - When Protocol to treaty itself provides for automatic application of amended provisions of treaty, even then Revenue can insist on separate notification to
< More News >
 
TII SPECIAL Nov 29, 2017
 
Can triple Cobweb of Info Exchange Net Tax Evaders?
By Naresh Minocha

IT is time to take a stock of ground covered by the world in tax transparency within the domain of tax administrations.

Organisation for Economic Co-operation and Development (OECD-hosted Global Forum on Transparency and Exchange of Information for Tax Purposes (Forum) released on 17th November its first report on the status

 
TII EDIT Nov 18, 2017
 
Digital economy to the fore again
By D P Sengupta

TAXATION of digital economy is still making headlines in policy circles all over the world. The OECD is working on it again; the EU is working on it. Most of the giant digital companies being American, the Trump/Republican tax reforms on which there is no consensus as yet in the USA, will also have

 
BULLETIN BOARD
 
New Delhi, Nov 14, 2017
Foreign Exchange Management (Transfer or Issue of any Foreign Security) (Amendment) Regula...
Mumbai, Nov 09, 2017
Govt notifies detailed amendments in FEMA Regulations for transfer of shares by a non-resi...
New Delhi, Nov 07, 2017
Clarification on Indirect Transfer provisions in case of redemption of share or interest ...
New Delhi, Oct 31, 2017
Vacancy at the level of Under Secretary in Foreign Tax & Tax Research Division of CBDT...
< More News >
 
TII BRIEF
 
Paris, Dec 12, 2017
CRS Disclosure - OECD seeks inputs on Model Disclosure Rules ...
New Delhi, Dec 07, 2017
Action 5 - Report on 44 tax jurisdictions released ...
New Delhi, Dec 05, 2017
South Korea, Macau & UAE figure in list of 17 tax haven blacklisted by EU ...
New Delhi, Dec 01, 2017
India signs two bilateral APAs with Netherlands ...
Paris, Dec 01, 2017
CbC Reporting - OECD releases additional guidance ...
 
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