India: Transfer Pricing Reporting Requirements
Recently India’s Central Board of Direct Taxes issued guidance that expands the transfer pricing reporting requirements of certain international transactions and certain “specified domestic transactions.” To bring into line those reporting
See MoreIndia: Extensive Guidance Note on APA
Recently the Central Board of Direct Taxes (CBDT) of India published a comprehensive APA Guidance Booklet concerning India’s advance pricing agreement (APA) program, detailing the procedural aspects of unilateral, bilateral or multilateral APA
See MoreIndia: Listed price cannot be used under the Comparable Uncontrolled Price (CUP) method
In a recent decision, the Chennai Bench of the Income-tax Appellate Tribunal held that the list price on a manufacture’s website is only an “indicative price” and so the list price alone cannot be used to determine the arm’s length price of
See MoreIndia: Requirements For Transfer pricing’s “deemed international transaction”
India’s transfer pricing rules are designed to prevent the use of transfer prices between related enterprises to shift profits away from India to a lower tax jurisdiction. The rules are therefore generally concerned with international transactions
See MoreIndia: Central government has issued Notification on transfer pricing tolerance band
If the transfer price charged by a taxpayer is within a certain percentage of the arm’s length price determined under section 92C of India’s Income Tax Act no adjustment is required. In previous years there has been some misunderstanding as to
See MoreIndia and Malta have signed a new Double Taxation Avoidance Agreement
India and Malta have signed a new Double Taxation Avoidance Agreement (DTAA) on April 8 2013. The provisions of the treaty generally follow the provisions of the OECD Model but the definition of a permanent establishment includes a building site or
See MoreIndia: Tax Court rules on selection of comparables
In determining transfer prices between a taxpayer and related parties one of the permitted methods is the transactional net margin method (TNMM). This compares profit margins to an appropriate base such as sales, assets or costs realized from a
See MoreIndia: Guidelines for application of the profit split method
India’s Central Board of Direct Taxes (CBDT) has issued Circular No. 2 of 2013, setting out guidelines for application of the Profit Split Method (PSM) in international transactions. The profit split method is one of the permitted methods for
See MoreIndia: Budget for 2013
According to the Indian Budget 2013, the Government is considering for following major tax initiatives: the introduction of a Direct Tax Code (DTC), a goods and services tax (GST) and General Anti-Avoidance Rules (GAAR). The main changes are
See MoreIndia: General Anti-Avoidance Rule For 2014
The General Anti –Avoidance Rule (GAAR) of India had been scheduled to be implemented from April 2014. After further consultation the provisions will however now come into effect from April 1, 2016 and these provisions would be used to target only
See MoreDTA between India and the UK
The UK tax authority, HM Revenue and Customs, has confirmed that a Protocol to the double taxation agreement (DTA) between India and the UK was signed on October 30,
See MoreIndia: Reduces tax rate on foreign borrowings
The Indian government has lowered the taxes charged on money borrowed by Indian companies in foreign currency. The changes are included in Finance Act 2012, which amends section 115A of the Income Tax Act and inserts a new section, 194LC, in the
See MoreIndia: Approves investor tax relief scheme
India's Finance Minister Shri. P. Chidambaram has approved a new tax relief scheme targeted at first time retail investors in the securities market. The Rajiv Gandhi Equity Saving Scheme (RGESS) will provide tax benefits to those investing up to
See MoreSri Lanka and India will soon sign a DTA
Sri Lanka and India will soon sign a double taxation agreement (DTA), an official from the Sri Lanka government said on July 12, 2012, following approval of a draft agreement by Sri Lanka's
See MoreAmendment to DTA between India and Japan enters into force
On May 24, 2012, the Indian government published a notification announcing the entry into force of an amendment to the DTA between India and Japan. The revised provisions became effective on April 1,
See MoreLithuania ratifies the DTA signed with India
Lithuania on May 4, 2012 ratified the double taxation agreement (DTA) the nation signed with
See MoreIndia- introduction of an APA program
The Finance Minister of India introduced the Finance Bill, 2012, on 16 March 2012 in which with respect to transfer pricing, the introduction of an advance pricing agreement (APA) program as well as other transfer pricing-related items has been
See MoreIndia’s Indirect Tax Revenues Peak
India's indirect tax revenue rose 9.6% in February, with the government having now collected 88.7% of its revenue target for the fiscal year to date. The latest statistics show that indirect tax revenue collections hit INR314bn (USD6.3bn), up 9.6%
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