India transfer pricing specialist Ajit Jain discusses the government’s June 7 decision to add a new transfer pricing safe harbor for low-value adding intragroup services and reduce existing safe harbor margins for knowledge process outsourcing services, contract research and development services, and other services.. . . .
Davide Anghileri of the University of Lausanne discusses Switzerland and India’s November 22 signing of a joint declaration on the introduction of automatic exchange of information in tax matters . . .
Liechtenstein and India may soon negotiate. . .
Mansi Seth, head of Nishith Desai Associates’ US practice, and Ashish Sodhani, a senior member of the firm’s international tax practice, discuss the renegotiated India-Cyprus tax treaty, which provides for source-based taxation of capital gains arising from alienation of shares . . .
Mansi Seth and Joachim Saldanha of Nishith Desai Associates discuss an October 24 Indian tribunal decision which held that payments made by Google India to Google Ireland for marketing and distribution of online ad space through the Google’s AdWords program were royalty payments subject to withholding tax . . .
See: Central Board of Direct Taxes.
*This guidance will be analyzed in a forthcoming MNE Tax article.
India’s Central Board of Direct Taxes (CBDT) has issued draft tax regulations on the indirect transfer abroad of Indian assets and has requested stakeholder feedback on guidance to implement India’s general antiavoidance . . .
The US IRS today confirmed that, beginning February 16, the US competent authority will accept applications for Indian advance pricing agreements (APAs), citing. . .
The revised India-Cyprus tax treaty, signed November 18, has entered . . .
India transfer pricing and tax litigator Ajit Jain discusses new transfer pricing rules providing for secondary adjustments . . .
See: Central Board of Direct Taxes. *The circular will be analyzed in a forthcoming MNE Tax article.
Mansi Seth, US practice leader at Nishith Desai Associates in New York, and Shipra Padhi, a senior international tax specialist based in the firm’s Mumbai office, discuss how the taxation of foreign investment in India will change as a result of the renegotiation of the India-Mauritius tax treaty . . . .
Reassured by the successful settlement of numerous long-pending transfer pricing disputes, the US competent authority has agreed to soon begin negotiating bilateral advance . . .
Update (2/1/2016): US confirms it will accept Indian bilateral APA applications: The US IRS, on February 1, confirmed that, beginning February 16, the US competent authority will accept applications . . .
Source: Vodafone: Income Tax department seeks Rs 32,320 crore from Hutchison over Vodafone deal – The Economic Times
Ashish Sodhani and Ameya Mithe of Nishith Desai Associates provide a comprehensive analysis of India’s new guidelines for determining a foreign company’s place of effective management . . .
BRICS leaders, following their summit held October 15–16, called for tax policies that promote inclusive growth and expressed support for the implementation of the OECD/G20 base erosion profit shifting . . .
Officials from six countries today signed a multilateral agreement that sets out the parameters for the automatic exchange of country-by-country reports on large multinational corporations. China, India, Canada, Iceland, Israel, and New Zealand joined 33 other countries that have . . .
India and the UK have signed two bilateral advance pricing agreements (APAs) to resolve transfer pricing disputes, the first such agreements between the nations, India’s . . .
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