1. Amends Rules 10DA and 10DB of the Income-tax Rules dealing with Master file and CbCR reporting for specified transactions of constituent entities of an international group; 2. Increases consolidated group revenue threshold to determine reporting eligibility from INR 5,500 crores to INR 6,400 crores.
Category: Updates
Vodafone International Holdings BV (The Netherlands) vs. India PCA Case No. 2016-35
In the given case, Vodafone had invoked Clause 9 of the Bilateral Investment Treaty (BIT) signed between India and the Netherlands to challenge the retrospective amendment to tax capital gains of Rs 22,100 crore. In a unanimous decision, the Permanent Court of Arbitration at The Hague has held that the retrospective demand was “in breach of the guarantee of fair…
Tax Updates- August ’20
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Tax Updates-July, ’20
Sharing with you “Tax Updates and Compilation of Judicial Rulings of Supreme Court, High Court, Income Tax Appellate Tribunal including rulings in the area of International Taxation and Transfer Pricing_July ’20”. Hope you may find it useful and informative too. Please visit the below link for detail: #taxation #internationaltax #transferpricing
UN Committee approved Transfer Pricing Manual Updates
Approved documents include: 1. Revised Chapter B.2 on comparability: Revisions were designed to provide consistency between UN TP Manual and the Platform for Collaboration on Tax’s comparability toolkit. 2. Revised Chapter B.5: On group synergies, which includes additional guidance on centralized procurement functions. 3. Approved Chapter B.9.4: On financial transactions dealing with guarantees. 4. Revised Chapter C.1: Which merges the…