All posts by nangia

Tax & Regulatory Newsletter – May 16 – May 31, 2017

We are pleased to share herewith the Tax & Regulatory Newsletter – May 16 – May 31, 2017 highlighting major recent tax and regulatory developments in India. Inside this issue… DIRECT TAX                                                                                                                                                      
  1. Payment made under membership agreement by the member entity not taxable on the principle of mutuality, thus no obligation to withhold tax
  2. Depreciation claim on government approvals and non-compete fees disallowed by Tribunal
  3. CBDT notifies the transactions of listed equity shares not eligible for Long Term capital gains exemption
 INTERNATIONAL TAX
  1. Mauritian Prime Minister during his Budget 2017-18 speech announces some major reforms to strengthen the tax environment of Mauritius
  2. Italy offers ‘webtax’ to IT companies, ensuring no tax disputes
  3. US’s Border Adjustment Tax
TRANSFER PRICING
  1. The taxpayers are required to furnish adequate rationalities before the appellate authorities to contradict its own position taken earlier while benchmarking the transactions with its associated enterprises
  2. The ITAT found the AMP intensity adjustment, applied by TPO by considering the AMP expenditure of the taxpayer as a separate ‘function’, reasonable and in-line with the High Court’s view in case of Sony Ericsson
Hope you will find it interesting and informative.   Click here to read the Newsletter: http://bit.ly/2shPbPG  

Changing The World’s Tax Treaty Network In One Stroke Of A Pen – Rakesh Nangia

Nobody anticipated that the Base Erosion and Profit Shifting (BEPS) project initiated by the Organisation for Economic Co-operation and Development (OECD) in 2013 could have such a significant impact on bilateral treaties around the world. Skepticism prevailed in the minds of all international tax bodies, regarding the effectiveness of OECD’s BEPS project, in implementing the proposed measures into the existing tax treaty network. Rakesh Nangia, Managing Partner and Neha Malhotra,  Executive Director contributed an article on  Changing The World’s Tax Treaty Network In One Stroke Of A Pen for BloombergQuint Rakesh Nangia - Worlds tax Treaty