Greetings!
We are pleased to attach herewith the Tax & Regulatory Newsletter for April 16- May 31st, 2018 highlighting major recent tax and regulatory developments.
Inside this issue…
DIRECT TAX
- Marketing support services availed by BPO to expand its market outside India is not chargeable to tax in India – Kolkata ITAT
- Bengaluru ITAT reaffirms payment for adwords program as royalty in case of Google India
- ITAT: Franchise agreement doesn’t create Indian PE for dominos
- CBDT issues notification for start-up companies seeking exemption from provisions of section 56(2)(Viib)
- CBDT issues instructions to smoothly implement the income tax provisions concerning start-up companies
- US-China trade war is back on: White House repeats threat to tax Middle Kingdom imports
- Silicon Valley tsunami? Tax plans aimed at Apple, Google could start a new wave, city leaders say
- Canadian economic policies in hot seat after U.S. tax changes
- Amazon, EBay Put Spotlight on Rivals in U.K.’s Tax Fraud Fight
- Merkel proposes new data tax
- HC upheld ITAT’s invocation of Rule 10B for allowing capacity utilization adjustment to manufacturer taxpayer
- ITAT discards WDV based benchmarking of purchase transaction and agrees to take customs/DCF/chartered engineer’s valuation.
- ITAT directed TP Provisions not applicable once transaction proved as sham
- ITAT holds that Revenue can determine taxpayer’s ALP, despite of AE’s Income acceptance, considering likely base erosion
- ITAT deletes TP-adjustment on corporate guarantee and remits ALP computation of interest on convertible debentures
- ITAT rejects Nil-ALP determination in respect of royalty payment and discards adoption of foreign comparable for benchmarking brand royalty