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Let's dive into PepsiCo case of Australia (See TII EDIT) I-T - Receipts derived from providing flight simulator services cannot treated as fee for technical services: ITAT (See Breaking News) I-T - If AE has been already remunerated at arm's length consideration basis TP principles in offshore sales, no further profits can be attributed to assessee: ITAT (See Breaking News) I-T - Technology embedded/ shrink wrapped in security software, cannot be characterised as rendering of technical service: ITAT (See Breaking News) TP - Concept of netting of overdue receivable against overdue payables comes into operation only in case where assessee is having overdue receivable and overdue payable from single AE or very same AE: ITAT (See Breaking News) Geopolitical tensions reshaping international cooperation in STI (See BRIEF) I-T - Reimbursement of communication & connectivity charges on cost to cost basis, does not attract TDS liability: ITAT (See Breaking News) I-T- Dividend Distribution Tax is tax on company's profits & not on dividend income of shareholders - provisions of DTAA do not apply to cap DDT; hence refund of excess DDT unwarranted: ITAT (See Breaking News) TP - Company engaged in manufacturing components for four wheeler in commercial and passenger vehicles category, cannot be compared to company which serves two wheeler vehicle industry: ITAT (See Breaking News) TP - Assessee which was providing SDS to its AE, company that was subsidiary having considerable brand value and turnover greater than assessee, could not have been accepted as comparable: ITAT (See Breaking News) CBDT notifies India-Qatar DTAA & Protocol TP - While bank guarantees issued by financial institutions to third-party independent entities are distinct in terms of risk profile from corporate guarantees issued between related parties, they are nonetheless functionally comparable: ITAT (See Breaking News) TP - There is no need to demonstrate need/ benefits ripen from any services rendered by AE: ITAT (See Breaking News) I-T - After amendment in Sec 40(a)(i), no disallowance under this section is to be made, if assessee has deposited TDS even in case of non-resident payee before due date of filing of return: ITAT (See Breaking News) TP - Differences in FAR analysis and turnover filter, calls for exclusion of comparable: ITAT (See Breaking News) I-T - If AO who had issued reopening notice u/s 148, was not having jurisdiction on case of assessee, then such notice becomes invalid due to jurisdictional defect: ITAT (See Breaking News) TP - No ALP adjustment with respect provision of non-binding investment advisory services is permitted by adding markup, if assessee was already reimbursed at cost plus 22% basis by its AE for such services: ITAT (See Breaking News) I-T - Payment of transponder service fees are not liable to TDS u/s 195: ITAT (See Breaking News) I-T - AO shall not disallow assessee's claim of payment of Cess by merely observing that expenses claimed in nature of Cess are not allowable as per Sec 40A(ii), without identifying exact nature of such ‘Cess': ITAT (See Breaking News) TP - Market value of power supplied by CPP to industrial unit shall be computed by considering rate at which State Electricity Board supplied power to industrial consumers in open market and not by comparing it with rates sold to Electricity Board: ITAT (See Breaking News) I-T - If AO has applied his discretion and reached plausible conclusion based on material on record, then revisionary authority cannot invoke sec 263 merely because it holds different opinion: ITAT (See Breaking News)
 
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Energy crisis drives fall in tax levels in OECD countries
By TII News Service
Dec 06, 2023 , Paris

    

HIGH energy prices triggered by Russia’s war of aggression against Ukraine prompted governments to reduce excise taxes during 2022, leading to lower tax levels in many countries, according to new OECD analysis.

Revenue Statistics 2023 shows that the average tax-to-GDP ratio in the OECD fell by 0.15 percentage points (p.p.) in 2022, to 34.0%. This was only the third such decline since the Global Financial Crisis in 2008-09: the level fell by 0.6 p.p. in 2017 and by 0.1 p.p. in 2019.

Revenues from excise taxes fell as a share of GDP in 2022 in 34 of the 36 countries for which preliminary data is available, declining in absolute terms in 21 of these. In some countries, notably in Europe, these declines were related to reductions in energy taxes as well as lower demand for energy products. Revenues from value-added tax (VAT) also declined as a share of GDP in 19 countries, in part due to policies to cushion consumers against high prices for energy and food. 

The decline in revenues from excise taxes in 2022 was partly offset by increases in revenues from corporate income taxes (CIT), which rose as a share of GDP in more than three-quarters of OECD countries amid higher corporate profits, especially in the energy and agricultural sectors. CIT revenues in Norway rose by 8.8% of GDP due to exceptional profits in the energy sector.

Overall tax revenues declined as a share of GDP in 21 of the 36 countries in 2022, increased in 14 countries and remained at the same level in one. The largest decline was observed in Denmark (-5.5 p.p., to 41.9%) while the largest increases were seen in Korea (2.2 p.p., to 32.0%) and Norway (1.8 p.p., to 44.3%).

 
 
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