Thin Cap rules are based on globally acceptable principles. However, one must be cognizant of certain sectors like infrastructure, steel, construction which have hugely leveraged balance sheets.
The legacy issue of royalty taxability for use v/s right to use shrink wrapped software has been a matter of litigation for a very long period, especially under the Tax Treaty scenario.
The tax department today signed three advance pricing agreements (APAs) with taxpayers as it looks to reduce litigation by providing certainty in transfer pricing.
The tax department today notified rules for calculating 'fair market value' of assets located in India in case of indirect transfer by multi-national companies for the purpose of levying tax.
By: Ashwin Vishwanathan, EY
By: Rakesh Nangia, Managing Partner, Nangia & Co.
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The new regime will be applicable for computation of ALP of international transactions and specified domestic transactions undertaken on or after April 1, 2014, a notification said.
Transfer Pricing 360Â°: Apr â€“ Jun 2015
Union Budget 2015 should attempt to lay out a roadmap to achieve the goal of reduced litigation on transfer pricing. Here are some measures government can take in this direction.
Budget should issue a) rules for announcements that were made in the budget in July 2014, (b) clarifications and guidance on matters that were at the centre of controversy during the past few years like equity infusion, valuations, etc. and (c) tax administrations, infrastructure and approach.
In comforting news for taxpayers, the CBDT is moving efficiently and fast on its APA regime, as it has already signed its first bilateral advance pricing agreement with Japan.
Revenue secretary Shaktikanta Das says there is a need to move away from aggressive tax planning and assessments. He says the industry needs to work closely with the government to encourage a non-adversarial tax regime.
Godrej rates Modi government‘s performance as 8.5 on a scale of 10 as he is enthused about India getting back on high levels of growth led by policy changes from the new government.
This issue goes back to FY10 when Vodafone had issued around 2,89,000 shares which were valued at around Rs 8500 per share aggregating to around Rs 246 crore to its sister entity, Vodafone Teleservices India Holding Mauritius.
The income tax department has red flagged issuance of shares to Voda‘s parent in FY 09-10, alleging they were undervalued. This is similar to an ongoing dispute for previous fiscals where the department had added 1300 crore to Voda‘s taxable income.
External Affairs Minister Salman Khurshid met Secretary of State John Kerry yesterday and "discussed a range of issues of mutual interest, including "ongoing discussions on the civil-nuke deal."
Transfer Pricing: Un-Safe Harbour?
The provisions for transfer pricing safe harbour, which is aimed at reducing tax related litigations with multinational IT companies have been inserted in Income Tax Act 2009 and the rules for the same will be notified by September first week.
By: Rohan K Phatarphekar, KPMG India
Panel had submitted its report in September, 2012, suggesting parameters to identify contract R&D services provider with insignificant risk and application of profit split method, among others
Shell is calling it an anti-FDI tax. The Indian tax department says it's a simple case of underselling Indian assets - a disguised loan that should be subject to transfer pricing rules. Here‘s the back story
The income tax department had identified and slammed notices on 27 companies for undervaluing share sales to their associate companies during 2012-13; the finance minister P Chidambaram today said in a written reply to Loksabha.