Sunday , July 26, 2026 |   08:12:37 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
INTL - Pendency of reference before larger bench of Supreme Court does not automatically stay operation of established high court precedents: ITAT (See Breaking News) I-T - Cost recoveries by non-resident entity from its Indian affiliates for various intra-group services are not taxable in India as FTS: ITAT (See Breaking News) TP - Company engaged in both custom software development & sale of software products across diverse sectors without providing segmental financial details, is functionally dissimilar to captive service provider: ITAT (See Breaking News) DTAA - Support, management & coordination services do not satisfy make available test as no proprietary technology, skill, or know-how is transferred - consideration for the same is not FTS: ITAT (See Breaking News) TP - For eligible assessee covered by Sec 144C, final assessment order must still be passed within outer limitation prescribed u/s 153, r/w/s Sec 153(4) where TPO reference is made: ITAT (See Breaking News) TP - TPO not justified in narrowing down pool of comparable companies by manipulating manufacturing income filters & introducing arbitrary 2% advertisement cost cap exclusively for domestic assessment: ITAT (See Breaking News) I-T - First proviso to amended Sec 149(1) prohibited issuance of reassessment notice once that old limitation had lapsed: ITAT (See Breaking News) I-T - If salary are paid to overseas group entities by way of actual reimbursements, then no TDS is required u/s 195: ITAT (See Breaking News) DTAA - An agency Permanent Establishment cannot exist when agent acts in ordinary course of its business & is not wholly dependent on a single principal: ITAT (See Breaking News) TP - Comparable may survive functional challenge but still be excluded if it fails accepted quantitative filter such as related party transaction threshold: ITAT (See Breaking News) TP - Principle of consistency runs through previous years treatment of comparables, guarantee/comfort letter pricing: ITAT (See Breaking News) I-T - Receipts from sale of software cannot be taxed as royalty merely because customer receives limited right to use software: ITAT (See Breaking News) INTL - Per settled precedent, sale of software and ancillary support services cannot be taxed as royalty & consideration received therefor is not taxable as fees for technical service: ITAT (See Breaking News) Govt notifies amending Protocol to India-Sri Lanka DTAA Global Min Tax: Reform is on track, says OECD (See Brief) TP - If facts surrounding intra-group foreign currency loan remain unchanged from earlier years, arm's length interest rate should be consistently benchmarked in line with earlier decision: ITAT (See Breaking News) I-T - DRP mechanism u/s 144C does not operate outside or independent of limitation framework: ITAT (See Breaking News) TP - AO must pass final assessment order within stipulated period of one month; order passed beyond such period is barred by limitation: ITAT (See Breaking News) TP - Under TNMM, relevant parameter is operating profit, since PBT may include non-operating items and can distort real operating performance: ITAT (See Breaking News)
 
TII SEARCH
 
 
   
Home >> News Brief
 

IMF calls for more streamlining of withholding tax to facilitate capital market union
By TII News Service
Sep 11, 2019 , Washington

    

A Staff Discussion Note (SDN) issued by International Monetary Fund has called for streamlining of cross-border withholding tax procedures to facilitate capital market union (CMU) in Europe. As put by SDN, "Investors look for company information backed by reliable audits and comparable accounting standards, and weigh the tax treatment of the investment. The level of withholding tax rates matters, but so too does the ease of obtaining withholding tax relief or refunds". Captioned 'A Capital Market Union for Europe', SDN dated Sep 10, 2019, notes that EU treaties enshrine capital mobility among the "four freedoms". The other three are: free movement of goods, services and labour. Notwithstanding these, European capital markets are split along national lines. In both banking & capital markets, the focus is domestic. This insularity has increased in recent times with a strong homeward retrenchment of bonds and bank loans; although, more encouragingly, cross-border equity claims have risen steadily.

SDN has relied on a new survey of practitioners. It highlights informational issues in securities markets and in withholding tax relief or refund procedures. The Note focusses on more-efficient withholding tax refund procedures. Survey participants noted that many investors may be subject to capital market taxes in both their country of residence and the country where the investment is realized, and that this double taxation limits appetite for such investments. Reducing delays and uncertainties in establishing eligibility for withholding tax exemptions was strongly favoured across the board.

SDN has pitched for three policy priorities, focused on the three barriers. First, transparency can be enhanced by requiring centralized, standardized, and ongoing reporting by all issuers; addressing challenges to the affordability of research on small issuers and unlisted firms;and streamlining cross-border withholding tax procedures. Second, regulation can be sharpened by centralizing oversight of systemic intermediaries; strengthening supervisory convergence tools to buttress investor protection where it falls short; taking further steps to support a cost-efficient, tax-effective, portable pension product; and pursuing close regulatory cooperation with non-EUcountries. Third, insolvency processes can benefit from a "name and shame" approach involving the setting of minimum standards and systematic monitoring of countries' progress in observing them. As put by SDN, "There is no roadblock—such steps should prove feasible without a new grand bargain".

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.