With an ever-evolving global taxation landscape, it has become essential to be in sync with the changing rules and regulations. The OECD BEPS global tax agenda has led to various countries proposing/implementing changes in their local laws to align with the themes laid out in the BEPS Action Plans. Recently the OECD released the text … More The road to counter BEPS
Unveiling the Budget 2016–17, Mr. Arun Jaitley, the Finance Minister, stated that the Budget proposals were built on the agenda of “Transforming India” with “nine distinct pillars”, including tax reforms, promoting ease of doing business and ensuring fiscal discipline.
Worldwide, trade balances are in a state of flux. Large multi-national enterprises (MNEs) of the world are raking in profits; however, are they paying their fair share of corporate tax or are they resorting to aggressive tax planning? Governments are looking for ways to recover public deficits by expecting MNEs to pay their “fair share … More BEPS and the Transactions landscape
OECD issued the Final Reports on the 15 Action points announced under Base Erosion and Profit Shifting (BEPS) Projectproviding governments with much needed ammunition to close the gaps in the existing international rules that allow corporate profits to “disappear” or be artificially shifted to low/no tax environments, where little or no economic activity takes place … More Impact of BEPS on transfer pricing documentation (Action 15)
Over several decades and in step with the globalization of the economy, world-wide intra-group trade has grown exponentially. Transfer pricing rules, which are used for tax purposes, are concerned with determining the conditions, including the price, for transactions within a multi-national enterprise (MNE) group resulting in the allocation of profits to group companies in different … More BEPS, value creation and transparency
“Coherence”, “transparency” and “substance” – these words have become the focal point of every discussion surrounding transactions today. In India, the glass ceiling on the importance of these terms was broken a few years ago with the advent of GAAR in the Direct Tax Code and retroactive amendments for taxation of indirect transfers. However, the … More Transactions in the BEPS world: the road ahead
The Finance Minister, in his Budget speech in 2014, had announced that range concept for determination of arm’s length price (ALP) will be introduced in the Indian transfer pricing regime where there is adequate number of comparables for determination of ALP. Furthermore, it was announced that use of multiple year data will be permitted for … More ‘Range Concept’ and use of ‘multiple years’ : Better late than Never