We are pleased to attach herewith the Tax & Regulatory Newsletter for June 01- June 30, 2018, highlighting major recent tax and regulatory developments.
Inside this issue…
DIRECT TAX
- AAR: US-parent Co’s income from authorised Indian reseller for content delivery solutions not taxable
- Mumbai Tribunal holds capital gains earned by Singapore Company from trading in Indian securities as non-taxable in India
- Ahmedabad ITAT: Mere TRC non-furnishing cannot disentitle treaty benefits; Explains Section 90(4) interplay vis-à-vis treaty override u/s. 90(2); at the same time Taxpayer must submit supporting documents to substantiate tax residency in country, whose tax treaty benefits are sought
- Delhi ITAT special bench holds that Nokia’s subsidiary doesn’t constitute the PE of Nokia Networks
- Time to ‘definitively address’ Ireland’s tax haven reputation
- Dividends Soar to Record After Tax Cuts and Bank Stress Tests
- German tax law permitting loss carry forward following restructuring of failing companies is not State aid, EU court rules
- UK tax treaty anti tax avoidance changes to apply from 2019
- OECD Welcomes Dutch Efforts To Counter BEPS
- ITAT deletes adjustment on Advertisement, Marketing and promotional expenses in the absence of any prior agreement or arrangement with the AE
- ITAT Deletes TP-adjustment on interest-free advances for equity investment
- ITAT: Rejects bank quotes average as guarantee ALP; Averages don’t always give logical results
- ITAT held that attribution of profits to Indian Branch should be based on FAR Analysis