India–MNE Tax

Asia-Pacific

US trade report says India’s equalisation levy impedes trade, risks retaliation: Kirtika Suneja / The Economic Times→

April 29, 2020

Asia-Pacific

India’s new 2 percent equalisation levy on the digital economy enters into force

April 22, 2020

Vinita Krishnan and Jugal Mundra, Khaitan & Co, Mumbai, discuss in detail India’s new 2 percent equalisation levy, which became effective on April 1 and applies to a broad range of nonresident e-commerce sales and services to Indian customers . . .

Asia-Pacific

India’s tax response to coronavirus

March 29, 2020

Ritu Shaktawat, a tax partner at Khaitan & Co, Mumbai, discusses tax measures announced by the Indian government on March 24 in response to the coronavirus pandemic . . .

Asia-Pacific

India’s Authority for Advance Rulings denies tax exemption under India-Mauritius treaty

February 24, 2020

Ritu Shaktawat, a partner at Khaitan & Co, Mumbai, India, discusses a controversial ruling released February 17 by India’s Authority for Advance Rulin which denied a capital gains tax exemption under the India – Mauritius tax treaty to a Mauritian entity . . .

Asia-Pacific

India’s cabinet approves protocol to treaty with Sri Lanka that includes BEPS minimum standards: Indus Dictum→

February 12, 2020

Asia-Pacific

India budget amends key tax rules affecting foreign investors

February 1, 2020

Rajesh H. Gandhi and Gaurav Chandak of Deloitte Haskins & Sells LLP, Mumbai area, India, provide a comprehensive assessment of the tax provisions in today’s India budget that are of interest to foreign investors . . .

Asia-Pacific

India retail trade group stages protests in 300 cities over Amazon founder Jeff Bezos’ India visit citing Amazon practices such as GST and income tax avoidance: MENAFN.COM→

January 16, 2020

Asia-Pacific

Australia releases synthesized text of tax treaties with Ireland, India reflecting MLI changes

December 3, 2019

The Australian government on November 29 released the synthesized texts of tax . . .

Africa

BRICS countries look forward to further progress on two-pillar approach to address digitalization: BRICS Information Centre→

November 18, 2019

Asia-Pacific

G-24 opposes OECD Secretariat’s Pillar One compromise, seek greater allocation of profits to market and no exclusion for B2B transactions: Gireesh Chandra Prasad / Livemint→

November 15, 2019

Asia-Pacific

India dissatisfied with share of revenues from digital tax proposal, unnamed official says: Deepshikha Sikarwar / The Economic Times→

November 6, 2019

Asia-Pacific

OECD’s latest MAP review includes focus on India

October 30, 2019

The OECD on October 24 released its sixth round of Stage 1 of peer review reports on base erosion and profit shifting (BEPS) action 14, assessing India, Argentina, Chile, Colombia, Croatia, Latvia, Lithuania, and South Africa, writes Prabhakar KS of Shree Tax Chambers, Bengaluru, India . . .

Asia-Pacific

Indian court rules Hitachi Singapore’s liaison office is a permanent establishment

September 26, 2019

Chartered Accountants Deepak Manoharan and Nathansha Dilip discuss the Hitachi case, a landmark ruling where the Delhi bench of the Income Tax Appellate Tribunal concludes that a liaison office could be treated as a permanent establishment of a foreign entity in India . . .

Asia-Pacific

India specifies transfer pricing arm’s length tolerance range

September 17, 2019

Gaurav Jain, a chartered accountant, and Priya Bhutani discuss Indian guidance released September 13 addressing the transfer pricing arm’s length tolerance range for wholesale trading and other activities . . .

Asia-Pacific

Norway disallows Telenor losses claimed upon settlement Indian subsidiary’s bank guarantees: Reuters→

August 26, 2019

Asia-Pacific

India Budget 2019: key international tax and transfer pricing developments

July 7, 2019

Mukesh Butani and Shreyash Shah of BMR Legal Advocates discuss India Budget 2019 which includes a few proposals that will have a material impact on cross-border taxation and transfer pricing . . .

Africa

Switzerland to exchange financial account information with 33 more countries for tax purposes

August 15, 2019

Davide Anghileri of the University of Lausanne discusses an August 14 decision of Switzerland’s Federal Council confirming that Switzerland will exchange financial account information with 33 more reviewed partner countries . . .

Africa

CIAT database reflects progress made by 15 countries implementing BEPS recommendations

August 9, 2019

In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .

Asia-Pacific

Amended India-China tax treaty protocol enters into force

July 19, 2019

An amending protocol to the China-India tax treaty has entered into force according to a July 17 notice of the Indian government, writes Prabhakar KS of Shree Tax Chambers . . .

Asia-Pacific

India ratifies multilateral tax convention

June 13, 2019

Prabhakar KS of Shree Tax Chambers, Bengaluru, India, discusses the June 12 ratification by India of the Multilateral Convention to implement the Tax Treaty related measures to prevent Base Erosion and Profit Shifting (MLI) almost 2 years after signing it . . .

Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

Ukraine today deposited with the OECD legal documents ratifying . . .

Asia-Pacific

India-Marshall Islands tax information exchange agreement enters into effect

May 26, 2019

Prabhakar K S, Proprietor of Shree Tax Chambers, Bengaluru, Karnataka, India writes that on May 21 India announced that a tax information exchange agreement between India and the Marshall Islands entered into effect . . .

Asia-Pacific

India deposits MLI ratification instrument with OECD

June 26, 2019

India deposited with the OECD documents ratifying the Multilateral Convention to Implement . . .

Asia-Pacific

India urges digital tax solution based on ‘significant economic presence’ at G20 finance ministers meeting: KNN→

June 10, 2019

Asia-Pacific

India considering barring auditors from more categories of non-audit work, official says: Injeti Srinivas / Live Mint→

May 13, 2019

Asia-Pacific

India defers GAAR reporting provisions

May 14, 2019

Prabhakar K S of Shree Tax Chambers writes that the Indian government, on May 14, for the second time deferred reporting requirements for general anti-avoidance rule (GAAR) compliance . . .

Americas

US formally asks the EU to “ditch” digital tax

October 22, 2018

Alan Rhode, co-founder of Taxmen.eu, discusses a US Senate Finance Committee letter, released last week, challenging the EU digital services tax, as well the latest positions of EU countries on the controversial proposal . . .

Asia-Pacific

India, Netherlands negotiating tax treaty amendment to plug share transfer loophole: Gireesh Chandra Prasad / LiveMint→

April 10, 2019

Americas

India, US sign agreement for exchange of country-by-country reports: Hindu Business Line→

March 27, 2019

Asia-Pacific

Proposed India profit attribution rules reject OECD approach, add “sales” and “users” as apportionment factors

April 24, 2019

Madhan N of PricewaterhouseCoopers Private Limited, India, discusses the Indian government’s controversial proposal for new rules for attributing profits to Indian permanent establishments . . .

Asia-Pacific

Indian advance pricing agreement uses customs value as arm’s length price

March 30, 2018

Mumbai advisor Ajit Jain writes that India’s Central Board of Direct Taxes has recently entered into an advance pricing agreement where customs values was accepted as arm’s length price for transfer pricing purposes . . . .

Asia-Pacific

India hits the 200 APA milestone, signs first pact on advertising, promotional expense

March 5, 2018

Transfer pricing and tax litigator Ajit Jain discusses India’s recent progress signing advance pricing agreements with multinationals and notes that the first unilateral APA dealing with the controversial topic of advertisement marketing, and promotional expenses has been concluded . . .

Asia-Pacific

India stays operation of circular on taxation of indirect transfers of assets

January 17, 2017

India’s finance ministry on January 17 announced that it will suspend the operation of a circular issued last month concerning the taxation in India of indirect transfers of Indian assets through offshore . . .

Asia-Pacific

India-Kuwait tax treaty protocol enters into force

May 7, 2018

India’s Central Board of Direct Taxes on May 7 announced that a protocol amending the 2006 India-Kuwait double tax treaty . . .

Asia-Pacific

Cognizant’s Indian subsidiary hit with Rs 2,500 crore (USD 375 million) tax bill from transfer pricing adjustment: Hemamalini Venkatraman / DT Next→

January 9, 2018

Asia-Pacific

India, Austria tax treaty protocol signed

February 7, 2017

Indian and Austrian government officials on February 6 signed a protocol to their 1999 tax treaty that would broaden the scope of the countries’ existing framework of exchange of tax. . . .

Asia-Pacific

India, US reach agreement on country-by-country reporting for multinational groups

March 19, 2019

Madhan N, a partner at PricewaterhouseCoopers Private Limited, India, writes that the US and India have agreed to a country-by-country report exchange framework that will affect on MNE filing requirements . . .

Asia-Pacific

India confirms intent to sign BEPS multilateral instrument curbing tax avoidance

May 17, 2017

Mansi Seth and Afaan Arshad of Nishith Desai Associates discuss today’s announcement that the Indian Union Cabinet has approved India’s signing of the multilateral instrument (MLI) to implement the tax treaty measures in the OECD/G20 base erosion profit shifting (BEPS) action plan . . .

Asia-Pacific

India-Korea tax treaty enters into force

October 27, 2016

A double tax treaty signed by India and Korea on May 18, 2015, entered into force on September 12, the government of India announced . . .

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin