India–MNE Tax

Africa

UN updates transfer pricing manual for developing countries

April 28, 2021

The United Nations’ latest edition of its practical manual on transfer pricing for developing countries, released April 27, adds new content on financial transactions . . .

Americas

US Treasury Secretary Yellen says tax moves needed to help tackle climate change

April 22, 2021

US Secretary of the Treasury Janet L. Yellen spoke on April 21 of the Biden administration’s “whole-of-government approach” to aggressively tackling climate change – including creating a targeted investment tax credit . . .

Asia-Pacific

India reduces transfer pricing filing burdens, increases reporting thresholds

April 13, 2021

Gaurav Jain, Chartered Accountant, and Priya Bhutani, New Delhi, India, discuss April 5 amendments to India’s transfer pricing guidance relating to the master file and country-by-country reporting . . .

Americas

India unlikely to agree to global minimum tax: Arup Roychoudhury / Moneycontrol→

April 9, 2021

Africa

Insight into the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation

April 8, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, examines the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation . . .

Americas

US threatens tariffs against six more nations over digital taxes, drops investigation into others

March 29, 2021

The US Trade Representative has recommended trade actions against Austria, India, Italy, Spain, Turkey, and the UK following its findings that digital services taxes adopted by these countries discriminate against US companies. . .

Americas

13 trade associations object to India’s proposed equalisation levy expansion

March 26, 2021

A global group of 13 technology and business trade associations sent a letter on March 19 to the Indian Parliament urging it not to adopt amendments to the equalisation levy announced in the government’s proposed Finance Bill 2021–22. . .

Asia-Pacific

India appeals Cairn Energy USD 1.4 billion arbitration award: The Economic Times→

March 23, 2021

Asia-Pacific

India’s lower house passes Finance Bill, 2021: Hindustantimes→

March 23, 2021

Asia-Pacific

Transfer pricing for Indian software distribution affiliates

March 17, 2021

New York City economist, Dr. J. Harold McClure, notes that Indian tax authorities may take a closer look at transfer pricing following their loss in a landmark decision involving the taxation of foreign-based software providers . . .

Asia-Pacific

India will levy a 40% customs tax on imports of solar modules from April next year to cut dependence on foreign supplies and boost domestic manufacturing of the equipment: Energy Infra Post→

March 10, 2021

Asia-Pacific

UK’s Cairn Energy considers ways to monetize arbitration award it won against India in six-year USD 1.7 billion tax dispute: Business Today→

March 10, 2021

Asia-Pacific

India Supreme Court settles the debate – software sale is not taxable as royalty

March 10, 2021

Ritu Shaktawat and Krutika Chitre, Khaitan & Co, Mumbai, discuss the Supreme Court of India’s new landmark ruling putting to rest a long-standing contentious issue surrounding the characterization of income in the hands of non-resident software manufacturers . . .

Asia-Pacific

First Look: India Supreme Court settles long-running dispute over taxation of software payments

March 2, 2021

India’s Supreme Court today ruled that software payments made by Indian end-users or distributors and resellers to overseas . . .

Austria

Trade groups sue over Maryland’s controversial tax on digital advertising

February 22, 2021

Four organizations have joined in a lawsuit challenging a new Maryland state law levying a tax on digital ad revenue – the latest twist in an ongoing dispute with international implications. The US Chamber of Commerce, the . . .

Asia-Pacific

India files suit in Singapore High Court challenging Vodafone arbitration award: ET Telecom→

February 8, 2021

Asia-Pacific

India’s Budget – Implications for the international business community

February 3, 2021

Mukesh Butani and Seema Kejriwal, Partners at BMR Legal, provide a detailed look at the tax implications for the international business community of India’s financial year 2021-22 budget, which includes controversial changes to India’s equalisation levy . . .

Asia-Pacific

First Look: India’s Budget – A step towards clarity for foreign investor taxation

February 1, 2021

Mukesh Butani and Seema Kejriwal, of BMR Legal in Delhi, take a first look at the Indian government’s budget proposals for 2021–22, released today, focusing on several important proposals that affect international taxation . . .

Asia-Pacific

Cairn Energy threatens to seize Indian government assets overseas to enforce 1.2 billion tax arbitration award: Aditi Shah & Aftab Ahmed / Reuters→

January 26, 2021

Americas

US says Austria, Spain, UK digital taxes discriminate, warns on EU tax, three others

January 15, 2021

Digital services taxes enacted in Austria, Spain, and the UK discriminate against US companies within the meaning of Section 301 of the US Trade Act of 1974, the Office of the US Trade Representative . . .

Americas

US says Italy, India, Turkey digital services taxes are discriminatory, suspends France tariff action

January 7, 2021

Digital services taxes enacted in India, Italy, and Turkey discriminate against the United States; however, for now, no trade actions will be taken, the Office of the US Trade Representative . . .

Asia-Pacific

Energy giant Cairn wins Rs 8,000 crore (USD 1.2 billion) arbitration award in dispute with India over taxation of indirect transfer of assets: Dilasha Seth / Business Standard→

December 23, 2020

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Asia-Pacific

India expected to challenge Vodafone’s arbitration award in dispute involving taxation of indirect transfer of assets: Timsy Jaipuria / cnbctv18.com→

December 4, 2020

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Asia-Pacific

India retains transfer pricing tolerance range for 2019–20

October 30, 2020

Gaurav Jain, Chartered Accountant, and Priya Bhutani discuss an October 19 India Central Board of Direct Taxes announcement setting the transfer pricing tolerance range for 2019–20 . . .

Asia-Pacific

Vodafone wins tax dispute in international arbitration: India’s dilemma

September 29, 2020

Bijal Ajinkya, Ashish Mehta, and Krutika Chitre, of Khaitan & Co, Mumbai, discuss Telecom giant Vodafone’s win against the Republic of India in international arbitration, in a tax case involving the indirect transfer of assets, and India’s possible next steps . . .

Asia-Pacific

MasterCard’s application before India’s High Court: the equalisation levy dilemma!

August 25, 2020

Ashish Sodhani, Leader, International Tax, at Nishith Desai Associates, Mumbai, discusses the Delhi High Court’s August 18 ruling on MasterCard’s petition to stay payment of the equalisation levy. . . .

Americas

India’s Google tax contributes 1% of direct tax in IT hubs of Bengaluru and Hyderabad despite expansion to online e-commerce: Shrimi Choudhary / Business Standard News→

August 25, 2020

Asia-Pacific

India publishes synthesized text of tax treaty with Ukraine adding MLI changes: Government of India Income Tax Department→

August 19, 2020

Asia-Pacific

India issues comprehensive guidance on cross-border tax dispute resolution

August 11, 2020

Ritu Shaktawat, Partner, and Raghav Kumar Bajaj, Principal Associate, at Khaitan & Co, Mumbai, discuss India guidance, released August 7, on the procedure for resolving cross-border tax disputes under the mutual agreement procedure (MAP) set out in India’s tax treaties with other nations . . .

Asia-Pacific

Georgia publishes amended text of tax treaties with Iceland, Ireland, Finland, Luxembourg, Slovenia

August 10, 2020

Gela Barshovi a tax adviser and managing partner of TPsolution, Tbilisi, discusses the Republic of Georgia’s July 23 publication of the synthesized text of tax treaties with five countries, as amended by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting . . .

Asia-Pacific

Trump trade adviser Peter Navarro says tax incentives in Ireland, Singapore, Switzerland, India, China that lure pharmaceutical manufacturing away from US are a “significant” problem: Brian O’Donovan / RTÉ→

August 10, 2020

Americas

UN committee proposes new model treaty provision altering taxation of automated digital services

August 6, 2020

The UN Committee of Experts on International Cooperation in Tax Matters today released a proposed optional UN model tax treaty article that would grant additional taxing rights to countries where an automated digital services provider’s customers . . .

Asia-Pacific

India Supreme Court rules Samsung Heavy Industries’ project office is not a permanent establishment under tax treaty

August 3, 2020

Jitendra Jain, Executive Director, Transfer Pricing, PricewaterhouseCoopers Private Limited, discusses the July 22 ruling of the Supreme Court of India in the case of Samsung Heavy Industries Co. Ltd., concerning the preparatory or auxiliary activities exception to permanent establishment . . .

Asia-Pacific

India widens its digital tax net by enabling tax payments

July 16, 2020

Jaiman Patel, Partner – Transfer Pricing (Financial Services), at EY India, discusses the Indian government’s July 3 release of an amended tax form to enable payment of India’s new equalisation levy, a clear indication that the government will not heed requests to defer the reporting or payment of this new tax on nonresident e-commerce operators . . .

Americas

US to investigate digital services taxes in India, Brazil, Turkey, Indonesia, the European Union, five EU countries

June 2, 2020

The Office of the US Trade Representative (USTR) today announced that it has initiated an investigation into digital services taxes proposed or adopted in . . .

Asia-Pacific

India clarifies tax residency of ‘visiting’ individuals stuck in lockdown

May 12, 2020

Ritu Shaktawat a partner at Khaitan & Co, Mumbai, India discusses an Indian government tax circular issued on May 8 providing relief to individuals that needed to prolong their stay in India due to the COVID-19 emergency . . .

Asia-Pacific

US Chamber, 8 other lobbying groups urge India to delay equalisation levy: Aditya Kalra / Reuters→

May 6, 2020

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

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

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
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