A: Introduction An estimate shows that 60% of the global transactions are amongst the related parties in value terms. That means every second transactions in global trade is covered under Transfer Pricing regulations. In view of digitalisation of tax administration, …
read moreCase Study on “POEM”
Case Study on “POEM” (Place of effective Management) As per the tax laws in India, a resident is taxed on worldwide income; whereas, a non-resident is taxed only on the income which is received or accrues or arises in …
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read moreCross Border Transactions – Tax Risk
Conclusions may be drawn from the above are that the business should definitely manage these tax risk which can eat out his business completely by just becoming aware of the such situations which leads to tax risk.
read moreMultinational Enterprises (MNE) Taxation – 2 Pillar Solution
Multinational Enterprises (MNE) Taxation – Unilateral to Multilateral Solution to justify right of Tax of Market Jurisdictions Setting Context OECD/G20 Inclusive Framework on BEPS working on International collaboration to end tax avoidance and resolve challenges arising out of digitalization of …
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read moreRoyalty and FTS Taxability
Royalty and Fee for Technical Services (FTS) Taxable on Gross Basis or Net Basis- An Analysis Setting Context for Royalty and FTS Taxability :- Income from Royalty and Fee for technical Services are generally taxable in the hands Non-resident …
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read moreNon Resident Taxation
Royalty vs. Fee for technical services vs. Business Profit As per International tax rules for Non-Resident Taxation, specific income of Non-residents have been excluded from the business Income so as to give taxing rights to the source Countries in respect …
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read moreCommission to Overseas Agent – Taxable?
Commission to Overseas Agent- Is Fee for Technical Services? Commission earned by Non-resident overseas agent from an Indian Company- Whether Taxable in India? Firstly, Taxability of any income in the hands of non-resident is be determined as per the provision …
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read moreTax Avoidance Illegal Now?
International collaboration to end tax avoidance Gone are the days? When a MNE incorporated in a Country, while its POEM is in a tax heaven, its production is in another jurisdiction and customers are located in some other jurisdiction, can …
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read moreInternational Financial Services Centres
Role of International Financial Services Centres’s (IFSC) in India’s Growth Story – An Unfinished Agenda It is estimated that Indian households have accumulated considerable wealth outside the country; well beyond the present limits set by RBI. The ability of Indian …
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read moreTransfer Pricing – Practical Issues
Transfer Pricing – Practical Issues Series – 1/2021 Transfer pricing is one of the most litigated areas of International Tax around the World. There are so many controversies since the inception of the TP provisions in India in 2002. In …
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