Thursday , February 23, 2017 |   19:56:19 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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NEWS FLASH
 
IGST continues to be 'Apple of Discord' (See 'The Cob(Web)') I-T - Method for computing ALP can be changed at a later stage to arrive at better comparable: ITAT (See 'Breaking News') TP - Company having abnormality of profits and losses cannot be included as comparable for ALP determination: ITAT (See 'Breaking News') TP - Profit derived from sale of shrink wrapped software would fall under the head "business profit": ITAT (See 'Breaking News') I-T - Income generated from mere use of a common facility given by parent company cannot be considered as FTS: SC (See 'Breaking News') IT - Payment made in respect of 'Shrink wrapped' or 'off the shelf' copyrighted packaged software cannot be termed as royalty payment - ITAT (See 'Breaking News') I-T - Provisions of section 206AA are inapplicable in cases of non-residents payees who were not under an obligation to obtain PAN: ITAT (See 'Breaking News') TP - A functionally dissimilar company, which is amalgamated, having an intangible, cannot be compared with a captive service provider: ITAT (See 'Breaking News') TP - A case can be remanded to be decided on merit, when accountant report is produced in subsequent proceedings: ITAT (See 'Breaking News') Policy on foreign investment in Indian Stock Exchanges - amendment to paragraph 5.2.21 of 'Consolidated FDI Policy Circular of 2016' (See 'Press Note' in FDI) I-T - If there is no change in FAR analysis of two different FYs, MAP approved margin of one year can be applied to another year for benchmarking: ITAT (See 'Breaking News') Govt notifies all provisions of protocol amending India Israel DTAA TP - For determining comparability, annual report of company has to be given precedence over information obtained u/s 133(6): ITAT (See 'Breaking News')
 
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TII BREAKING NEWS
 
I-T - Method for computing ALP can be changed at a later stage to arrive at better comparable: ITAT
TP - Company having abnormality of profits and losses cannot be included as comparable for ALP determination: ITAT
TP - Profit derived from sale of shrink wrapped software would fall under the head "business profit": ITAT
I-T - Income generated from mere use of a common facility given by parent company cannot be considered as FTS: SC
< More News >
 
TII SPECIAL Feb 16, 2017
 
Analyzing Indian Thin Capitalisation Rules
By Yogesh Shah, Aparna Parelkar & Jolly Bajaj

THIN capitalisation refers to hidden equity capitalisation by borrowing higher level of debt as compared to equity and leveraging capital structure, which leads to reducing taxable profits to the extent of interest paid on debt borrowings. Multinational groups strategize their financing arrangements to create tax-efficient mixture of debt and equity in borrowing jurisdiction

 
TII EDIT Jan 23, 2017
 
Complexity of the Multilateral Convention for combating BEPS
By D P Sengupta

TAX treaties now have a long history starting from the year 1899. For most part, however, tax treaties are bilateral in nature. Although there are a few multilateral treaties like the Nordic Convention but these are between groups of homogeneous states. Taxation is intimately connected to the sovereignty of states and each state

 
BULLETIN BOARD
 
New Delhi, Feb 21, 2017
Govt notifies all provisions of protocol amending India Israel DTAA...
New Delhi, Jan 27, 2017
Clarifications on implementation on GAAR provisions under Income Tax Act, 1961 ...
New Delhi, Jan 24, 2017
Guiding Principles for determination of Place of Effective Management (POEM) of a Company...
New Delhi, Jan 13, 2017
Exchange facility to foreign citizens ...
< More News >
 
TII BRIEF
 
Paris, Feb 09, 2017
OECD/EU makes available database on affordable housing...
New Delhi, Feb 07, 2017
CBDT enters into four more APAs ...
New Delhi, Feb 06, 2017
India, Austria sign protocol to amend DTAA for exchange of tax info...
New Delhi, Feb 03, 2017
Govt trying to revise tax treaties to enable CBI to prosecute black money a/c holders...
New Delhi, Feb 02, 2017
WB to provide USD 201 mn for Technical Education Quality Programme...
 
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