Asia-Pacific
India
Asia-Pacific
Asia-Pacific
Asia-Pacific
Comments released on tax guidance addressing offshore indirect asset transfers
18 comment letters – including letters from the governments of India and China — were released today responding to a draft “toolkit” designed to help developing countries address the taxation of offshore indirect transfers of assets, a practice used by some multinational corporations for tax avoidance. The guidance was prepared by “Platform for Collaboration on Tax,” a joint effort of the IMF, UN, OECD, and . . . .
Asia-Pacific
Report details India’s plan for equalization levy to tax digital economy
The Indian government on Monday released a high level report that appears to have influenced Finance Minister Arun Jaitley’s budget proposal for a 6 percent equalization levy on e-commerce . . .
India
Indian tax agency announces signing of seven more APAs
India has signed seven more unilateral advance pricing agreements (APAs) with multinationals, India’s Central Board of Direct Taxes (CBDT) announced January 22. The . . .
Africa
Asia-Pacific
India to accept transfer pricing APA, MAP applications even if corresponding adjustment treaty provision absent
The Indian government today clarified that it will accept transfer pricing mutual agreement procedure (MAP) cases and bilateral advance pricing agreement applications in situations where the applicable tax treaty does not include a provision comparable to Article 9(2) of OECD Model Tax Commentary, providing for corresponding adjustments. A Central . . .
Africa
Asia-Pacific
High Court rules India can’t tax Dutch company’s sale of shares in Indian company that holds Indian immovable property
Joachim Saldanha and Ashish Sodhani of Nishith Desai Associates discuss a recent Indian High Court decision which concludes that gains arising from a Dutch company’s sale of shares of an Indian immovable property company to a Singapore company are not taxable in India under the India-Netherlands tax treaty . . .
Asia-Pacific
No changes planned for India-Netherlands tax treaty but BEPS multilateral instrument looms
Sriram Govind of the Institute for Austrian and International Tax Law discusses reports that India will not renegotiate its tax treaty with the Netherlands, as it did with Mauritius, Cyprus, and Singapore, and addresses the impact of the countries’ expected signing of the BEPS multilateral instrument . . .
Asia-Pacific
Rahul Mitra to lead KPMG India’s transfer pricing practice
KPMG India on June 6 announced the appointment of Rahul Mitra to head the firm’s transfer pricing practice. Mitra, a partner, will also continue to lead the firm’s efforts regarding . . .
Asia-Pacific
Asia-Pacific
India developing “significant economic presence” test to increase taxation of multinational firms
Nishith Desai Associates attorneys, Meyyappan Nagappan and Anandapadmanabhan Unnikrishnan, discuss the Indian government July 13 request for public feedback to aid in the development of a “significant economic presence” test, which is a nexus rule designed to expand India’s taxation rights over business profits of both digital and non-digital multinational firms . . .
Asia-Pacific
Indian tax tribunal adopts expansive view of permanent establishment in Mastercard ruling
India’s tax authority has won a sweeping victory before India’s Authority for Advance Rulings, convincing the tribunal on 6 June that Mastercard’s activities in India created a permanent establishment in India under several different theories, write Nishith Desai Associates attorneys Shipra Padhi and Anandapadmanabhan Unnikrishnan . . . .
Asia-Pacific
Indian flavors in transfer pricing master file, country-by-country rules
Jitendra Jain, Executive Director at PricewaterhouseCoopers, India, discusses India’s much-awaited rules on the implementation of the master file and country-by-country report, released yesterday, focusing on the differences between India’s master file requirement and the OECD’s prescribed format and recommending next-steps to comply with the requirements . . .
Asia-Pacific
India, Singapore sign tax treaty protocol: Central Board of Direct Taxes→
See: Release. The protocol will be analyzed in detail in a future MNE Tax article.
Asia-Pacific
India clarifies taxation of indirect transfers of assets abroad
India on December 21 set out a series of questions and answers clarifying the taxation . . .
Asia-Pacific
Asia-Pacific
Africa
BRICS country tax officials express support for “inclusive framework” on BEPS
Heads of revenue of the BRICS countries – Brazil, Russia, India, China, and South Africa – at a meeting held December 5–6 in Mumbai, expressed support for measures . . .
Asia-Pacific
Asia-Pacific
India’s Cabinet approves Belgium/India tax treaty protocol
India’s Cabinet has today approved a protocol to its 1993 tax treaty with . . .
Americas
Africa
Asia-Pacific
Americas
India extends FATCA due diligence deadline for accounts that become high-value
The Indian government has today announced that it has extended FATCA due diligence deadlines . . .
Asia-Pacific
Foreign companies with India PoEM subject to higher 40 percent tax rate, government concludes
Mohit Agarwal, a Tax Director at PwC India, discusses important guidance issued by the Indian government on June 22 relating to computation of tax liability, applicable tax rates, and related compliance once a foreign company’s ‘place of effective management’ (PoEM), and thus the company’s tax residence, is determined to be in India . . .
Asia-Pacific
India-Korea bilateral advance pricing agreements can include rollback, Indian tax board says
“Rollback” of a transfer pricing method to resolve disputes in previous open tax years is permitted for bilateral advance pricing. . . .
Asia-Pacific
India-Belgium tax treaty protocol signed
India and Belgium today signed a protocol to their existing tax treaty to broaden the scope of exchange of tax information between the countries, India’s . . .
Asia-Pacific
Asia-Pacific
Asia-Pacific
Africa
Switzerland consults on introducing automatic exchange of tax information with 22 countries
The Swiss government has today announced a consultation on commencing automatic exchange of information in tax matters with 22 countries, writes Davide Anghileri, a lecturer at the University of Lausanne . . .
Asia-Pacific
India clarifies FATCA and CRS requirements
India’s Income Tax Department today released guidance to help financial institutions comply with FATCA and the common reporting standard regarding account holder self-certification, collection . . .
Asia-Pacific
Asia-Pacific
Americas
Asia-Pacific
India’s multilateral instrument choices: a quick run-through
Sriram Govind, a research and teaching associate at the Institute for Austrian and International Tax Law, discusses India’s choices for the multilateral instrument and possible implications to its tax treaty network . . .
