India: Refurbish Tax Treaty with Cyprus

16 June, 2014

India is seeking an amendment to its 1994 double tax agreement with Cyprus before the territory can be out as a notified jurisdictional area. From November 2013, the Indian Government raised powers under Section 94A of the Indian Income Tax Act

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India: Businesses Meeting held For Tax Certainty

11 June, 2014

India's Finance Minister, held a discussion meeting with representatives from trade and industry bodies before the budget, which pressed the Government to familiarize expectable tax policies to adoptive greater confidence in India as a place to

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India: Mumbai Tribunal settles charge of penalty in case of a transfer pricing adjustment

10 June, 2014

Recently in the case of Deloitte Consulting India Pvt Ltd (Taxpayer) regarding levy of penalty in the case of a transfer pricing (TP) adjustment. Here is the summary of the case and decision: The Taxpayer, an Indian company, had entered into a

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India: Income-tax Appellate Tribunal found that no adjustment given taxpayer’s minimal risks, limited functions 

03 June, 2014

Recently, in the case of Marubeni Corp., Japan (ITA No: 5397/Del/2012) The Delhi Bench of the Income-tax Appellate Tribunal held that, a transfer pricing adjustment with respect to a taxpayer performing what were found to be low-end mediation

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India: Hyderabad Tribunal rules on transfer pricing aspects of corporate guarantee

20 April, 2014

The Hyderabad Income Tax Appellate Tribunal (ITAT) has issued a ruling that concerns certain transfer pricing issues from a corporate guarantee issued to a bank by associated enterprises of a borrower. The case is Four Soft Pvt Lrd. The case

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India shows decline in transfer pricing adjustments

07 April, 2014

The income tax department has estimated that the number of transfer pricing adjustments in 2014 so far has fallen by 14 percent by comparison to the previous year. This may indicate that taxpayers in India are becoming more aware of the transfer

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India releases revised Direct Taxes Code 2013

04 April, 2014

The Indian Finance Minister has issued a discussion draft of the Direct Tax Code (DTC), 2013. This draft contains proposals for extra taxes on high net worth individuals, a lower threshold than earlier proposed for imposing tax on the offshore sale

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Revision to treaty between India and Bulgaria

31 March, 2014

Bulgaria’s Ministry of Finance has been authorized to begin negotiations for a double tax treaty with India. After it has been signed and has entered into force the new treaty will replace the current treaty signed in

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India: Delhi Tribunal rules on transfer pricing aspects of intra group financing transactions

31 March, 2014

In India many transfer pricing cases are heard in the Courts. These decisions can provide clarification of the operation of the transfer pricing rules in India and can therefore give potential investors more certainty about the transfer pricing

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Treaty between India and Romania enters into force

24 March, 2014

The treaty between India and Romania which was signed on 8 March 2013 generally applies from 1 January 2014 for Romania and from 1 April 2014 for India. From this date, the new treaty generally replaces the India - Romania Income Tax Treaty in

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India: Tribunal finds reimbursed advertising expenses were at arm’s length

16 March, 2014

The Mumbai Bench of the Income tax Appellate Tribunal has upheld an administrative action by the Commissioner of Income tax, to reject a proposed transfer pricing adjustment for advertising expenses reimbursed by the taxpayer to its related

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United Kingdom – India DTA protocol

09 March, 2014

As notified by the Indian Ministry of Finance on February 10, 2014, the Protocol amending the India-UK double taxation agreement (DTA) entered into force in the UK and India on December 27, 2013. The DTA Protocol is immediately effective in India,

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Indian Government wants tax officials to be more friendly

09 March, 2014

The Indian Government has requested that tax officials act as "facilitators" rather than "administrators," and ensure that the taxation system is as taxpayer friendly as possible. The Finance Minister has suggested that procedures should be

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Indian Capital Gains Tax slows Saudi Investment

09 March, 2014

Concerns have been raised by foreign investors about the effect of India's taxation system, particularly its capital gains tax, on foreign investment. The issue was raised during the India-Saudi Arabia Business Forum in Delhi. The Forum also looked

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India: Income Tax department identifies 2.17 million potential non-filers

09 March, 2014

After sending notices to 1.21 million Permanent Account Number (PAN) cardholders who had not filed their income tax returns, the income tax department has now identified another 2.17 million potential non-filers. It had already sent letters to

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DTA between India and Malta enters into force

09 March, 2014

The new Income Tax Treaty and protocol between India and Malta entered into force on 7 February 2014 and will apply in India as from 1 April 2014 and as from 1 January 2015 in Malta. The new treaty was signed on 8 April 2013 and replaces the old

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Morocco & India: Amending protocol of DTA approved

24 February, 2014

The Moroccan Council of Government approved the amending protocol to the India and Morocco Double Taxation Agreement (DTA) on 20 February 2014  and it was signed on 8 August 2013, . The protocol applies mainly to the exchange of tax information

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India and Croatia Sign bilateral DTA

23 February, 2014

India and Croatia signed a Double Tax Agreement on 12 February 2014.  This move is seen as an important step in the strengthening of the two countries’ economic cooperation. No further details of the agreement are currently

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