India and US considering framework for resolving tax rows
India and the US could soon unveil details of a deal designed to resolve more than 100 outstanding tax disputes. The two sides almost finalized the outline of a mutual agreement procedure (MAP). Numerous discussions on the issue are said to have
See MoreDTA signed between Latvia and India
According to media reports, Latvia's parliament approved a law that would ratify the DTA and an accompanying Protocol signed between Latvia and India on December 19,
See MoreIndia is expected to post a Revenue Service office in Cyprus
India is expected to post a Revenue Service officer in Cyprus early in the new year, just months after it suspended its double tax avoidance agreement (DTAA) with the island. India has set up overseas Tax Units in various countries in an effort to
See MoreIndia – Arm’s length price for sourcing support services
The Delhi High Court has held that the Transfer Pricing Officer’s determination of an arm’s length price based on a 5% markup of the “free on board” (FOB) value of goods sourced for a related party’s contract with third parties was
See MoreIndia signs DTA with Macedonia to prevent income tax evasion
India signed a Double Taxation Avoidance Agreement (DTAA) with Macedonia on Dec 17, 2013, to prevent income tax evasion by entities in both the countries, a move that is also expected to increase economic cooperation. The agreement provides
See MoreIndia: Clarifies conditions of service tax amnesty
The Indian Finance Ministry has wanted to clarify concerns over its Service Tax Voluntary Compliance Encouragement Scheme (VCES) by commenting on issues raised by industry representatives. The Finance Minister recently settled a series of
See MoreTax treaty between India and United Kingdom – Indian decision on taxability of fees for technical services
The Indian Income Tax Appellate Tribunal (ITAT) issued its decision on 31 May 2013 in the case of Veeda Clinical Research Private Limited (ITA 1406/Ahd/2009) that the provision of market awareness and development in-house training services to an
See MoreIndia: Determines guarantee rates on loans are arm’s length
The Mumbai Bench of the Income-tax Appellate Tribunal held that bank guarantee rates cannot be mechanically applied in determining the arm’s length price. The tribunal explained the difference between corporate guarantee and bank guarantee, and
See MoreTechnical services fees under treaty between India and Germany
It was held by the Agra Bench of the Income-tax Appellate Tribunal of India that leather testing charges were taxable as “fees for technical services” under the India-Germany income tax treaty. The treaty allows the source state the right to tax
See MoreIndia: Determines arm’s length price of share transfers
The Income-tax Appellate Tribunal has held that the discounted cash flow method was preferable over the “yield” method or “net asset value” method for purposes of determining the arm’s length price of shares transferred to related parties.
See MoreCyprus – Effort to Resolve India Tax Treaty Suspension
The government of Cyprus is taking the initiative to resolve matters regarding the suspension of provisions within the tax treaty with India. The Indian government suspended the provisions of the 1994 tax agreement on 1 November 2013, with Cyprus
See MoreIndia – GST implementation hits new delays
The Indian government’s plans to introduce a new implementation Bill and to replace the existing Indian VAT and CENVAT regimes with a new Goods & Services Tax (GST) look likely to be delayed again since the States are seeking to re-open
See MoreIndia – Cyprus is identified as a “notified jurisdictional area”
The Finance Ministry of India has issued a release in which Cyprus is identified as a “notified jurisdictional area” with respect to transactions entered into by any Indian taxpayer with a person located in Cyprus. A transaction with a person in
See MoreCyprus and India held negotiations towards a revision of DTA
Cyprus and India held negotiations towards a revision to the countries’ double taxation agreement (DTA), to incorporate provisions on tax information exchange. The discussions continued over three days concluding on November 28,
See MoreIndia: Government will reduce E-Payment Threshold from 2014
The Indian Government decided to reduce the threshold limit of mandatory e- payment from January 1, 2014 with the Notification no. 15/2013-CE (NT) 22.11.13 and 16/2013- Service Tax 22.11.13 . From January 1, 2014 , Companies are essential to
See MoreIndia : Loan simplification services and fees of foreign branches
In a recent decision, the Mumbai Bench of the Income-tax Appellate Tribunal found that: Services provided by a taxpayer bank were “crucial services” and the services were not a “mere facilitation” for concluding or signing of the loan
See MoreIndia: Vodafone case regarding transfer pricing
The Bombay high court directed the income-tax department to stop the proceedings of its dispute resolution panel (DRP) against the Indian subsidiaries of Vodafone Group Plc and Royal Dutch Shell plc in an alleged transfer pricing case till the court
See MoreIn the Case of ADIT vs. Clifford Chance, the Tribunal ruled that professional services fees would be taxable in India
On 13 May 2013, the Special Bench of the Income Tax Appellate Tribunal issued its judgment in the case of ADIT vs. Clifford Chance. The Tribunal ruled that professional services fees would be taxable to the extent of the services actually
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