Indian Government drafts proposals for attribution of profits to permanent establishments (PEs) in India – Focus on India’s demand/market and deviation from TP principles

The attribution of profits to permanent establishment (PE) is one of the most litigated aspects of international tax in India. The Central Board of Direct Taxes (CBDT) had formed a committee to examine the existing scheme of profit attribution to PE and recommended changes. The committee’s draft report has been released by the CBDT[1] and … More Indian Government drafts proposals for attribution of profits to permanent establishments (PEs) in India – Focus on India’s demand/market and deviation from TP principles

GST audit – it is the time to reconcile

India has experienced the completion of its first financial year of the much-awaited Goods and Services Tax (GST) from 1 July 2017 to 31 March 2018. This contemporary regime held high aspirations digitally by mandating taxpayers to undertake transaction-level reporting of its business on to its information technology/Goods and Services Tax network (IT/GSTN) platform. It … More GST audit – it is the time to reconcile

Protocol amending India-China DTAA: Embracing the change!

India and China are two of the world’s oldest civilizations. Cultural and economic relations between China and India date back to ancient times. Despite political issues over the years, the relations between India and China have steadily improved and strengthened in various fields of mutual interest. Indian Prime Minister Narendra Modi and Chinese President Xi … More Protocol amending India-China DTAA: Embracing the change!

Unfolding the ESOPs’ taxation conundrum

Employees’ Stock Option Plans (ESOPs) form an integral part in the overall reward framework of an organization. In a typical ESOP, the company grants options to the employees. These options vest over a period of time, subject to certain conditions. On fulfilment of the vesting conditions, the employees get the right to exercise the options … More Unfolding the ESOPs’ taxation conundrum

Will the Government’s “digital” agenda fund the much-anticipated tax cuts in this Budget?

Like every other year, there are a number of “asks” the country (both individuals and corporates) may have from the Finance Minister this Budget — reducing corporate tax rates, doing away with dividend distribution tax and increasing the tax exemption limit to name a few. And as budgets go, something or someone may have to … More Will the Government’s “digital” agenda fund the much-anticipated tax cuts in this Budget?

Master file notification: Expectations, impact and risk areas for MNCs

The Organisation for Economic Co-operation and Development (OECD) commenced work on the Base Erosion and Profit Shifting (BEPS) project to address concerns that existing principles of domestic and international taxation were failing to keep pace with the global nature of modern business models. As a member of the G20 and an active participant in the … More Master file notification: Expectations, impact and risk areas for MNCs