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

SQL redefined: Silver lining or double-edged sword

TP litigation in India High-pitched transfer pricing (TP) assessments have been in headlines in India for about a decade now. The first round of TP assessments commenced during financial year (FY) 2004-05 and since then, the number of cases scrutinized and the quantum of TP adjustments have been rising with TP adjustments of approximately US$10.8 … More SQL redefined: Silver lining or double-edged sword

Is a surge in TP controversy post the MF and CbCR filing likely?

More controversy expected As Indian companies breathed a sigh of relief after meeting the first compliance deadline of filing of Country-by-Country report (CbCR) and Master File (MF), what could lie ahead is more controversy and questioning from tax authorities as they gain access to new sources of information and increased transparency across the globe. This … More Is a surge in TP controversy post the MF and CbCR filing likely?

Transfer pricing in 2017 and what it means for the future

Till a few years ago, the Union Finance Budget used to be the country’s signature tax event of the year. However, the recent past has seen tax-related changes roll in through the year, so much so that every month has taxpayers understanding and debating new developments, thereby consigning the Budget to a lower pedestal. The … More Transfer pricing in 2017 and what it means for the future

Blockchain technology: Possible future of digital transfer pricing

Change is certain, and the digital world is changing exponentially. It started with smartphones, which impacted the masses and led to the emergence of smart lives. As digitization and automation continue, it is now the time for smart businesses. Among many fast-emerging disruptive technologies, blockchain technology seems to have the potential to revolutionize businesses and … More Blockchain technology: Possible future of digital transfer pricing

Developments in International Tax: An update and its impact

OECD proposes changes to be incorporated in the 2017 update to the OECD Model Tax Treaty  The Organisation for Economic Co-operation and Development (OECD) on 11 July 2017 released the draft contents of the update to the OECD Model Tax Convention (the 2017 update). Among a number of other proposals, the 2017 update contains changes … More Developments in International Tax: An update and its impact