Asia-Pacific

Google India’s payments to Google Ireland for AdWords program are royalties subject to withholding tax, court rules

An Indian appellate court has ruled that payments made by Google’s Indian subsidiary to Google’s Irish subsidiary to operate the Google AdWords program in India were royalties subject to withholding tax and not payments to obtain advertising space for resale, as Google has claimed. The court also mandated the use of the profit split method for some related-party transactions. . .

Asia-Pacific

Cyprus, Saudi Arabia sign tax treaty 

The governments of Cyprus and Saudi Arabia signed a tax treaty on January 3, Cyprus’s Ministry of Finance has reported. The new tax pact is based on the OECD Model Convention for the Avoidance of Double Taxation on Income and on . . .

Asia-Pacific

India adopts controversial tax rules for valuing indirect transfers of assets

Mansi Seth, US practice leader at Nishith Desai Associates in New York, and Meyyappan Nagappan, a senior member of the international taxation team in the firm’s Mumbai office, discuss new guidance issued by the Indian tax authority to be used to determine the fair market value of indirect transfer of assets, stating that several aspects of the new rules are contentious and could lead to litigation . . .