Sriram Govind of the Institute for Austrian and International Tax Law discusses a circular issued by the Indian government January 27 which contains welcome clarifications on India’s coming GAAR but also includes statements that will likely increase confusion, such as how the GAAR will be applied in some cases involving tax treaties . . .
The Indian goverment has provided financial institutions with more guidance on how to handle currencies and fixed deposit accounts for purposes of Foreign Account Tax Compliance Act (FATCA) and common reporting . . .
India and Cyprus have completed negotiations for a new tax treaty that allows for source-based taxation of capital gains from the alienation of shares and have agreed to Cyprus’s removal from India’s blacklist of “notified jurisdictional areas,” Cyprus’s . . .
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. . .
A protocol to the Singapore-India tax treaty entered into force on February 27, Singapore’s Inland Revenue Authority has announced. One aim of the . . .
Japan’s Ministry of Finance today announced that two tax agreements will enter into force: a tax treaty with Germany and a protocol to a tax treaty with India. Notifications . . .
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 . . .
India and US tax officials have resolved 108 mutual agreement procedure (MAP) tax disputes and have reached agreement on the their first bilateral advance pricing agreement (APA), India’s Central Board of Direct . . .
Shri Sushil Chandra on November 1 took over the role of chair of India’s Central Board of Direct Taxes (CBDT), the Indian government has announced. He replaces former. . .
India’s Central Board of Direct taxes today released a notice announcing details of a new 6 percent tax that will be imposed on payments made to nonresidents for online advertising beginningr . . .
Bhavik Timbadia and Hussain Sunel of BMR & Associates LLP discuss the newly revised draft UN Practical Manual on Transfer Pricing for Developing Countries, focusing on the India chapter, which reveals Indian tax authorities’ current transfer pricing positions, including some surprising views on low value adding intra-group services . . .
The UN Committee of Experts on International Cooperation in Tax Matters (Committee) has released several reports in advance of its annual meeting, slated for October 11–14 in New York, revealing that significant changes to the UN transfer pricing manual and model tax convention are . . .
Jitendra Jain, Executive Director, PricewaterhouseCoopers, discusses final Indian rules for multinational taxpayers, released October 31, on the implementation of the transfer pricing master file and country-by-country report, noting that important changes were made to the earlier, draft version of the guidance. . .
India and Slovenia have signed a protocol to their tax treaty, agreeing to expand the scope of information exchange between tax authorities. . .
Mumbai chartered accountant, Ajit Jain, discusses progress and problems with India’s advance pricing agreement (APA) program . . .
Indian tax officials signed a record number of advance pricing agreements (APAs) in fiscal year 2016–17; nonetheless, India’s backlog of unresolved APA cases increased during the . . .
India and Kazakhstan have signed a protocol to amend their 1996 tax treaty, the
Indian government announced today. The new protocol . . .
The countries that have joined the inclusive framework established to carry out the work of the OECD/G20 base erosion profit shifting (BEPS) project are likely to eventually take on international tax work outside of the BEPS . . .
India and Mauritius today signed a protocol to their 1983 tax treaty, revising the tax treatment of capital gains on sales by Mauritius residents of . . .
UPDATE: Text of the India/Mauritius protocol published: The text of the new protocl has been published on the Mauritius goverment website. See: Protocol.
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