All posts by nangia

Test Ahead for India’s Intercompany Pricing Pacts – Nitin Narang

India is bolstering a tax program designed to reduce costly disputes with multinationals, after it came under criticism for being too burdensome. Advance pricing agreements (APAs) are ahead-of-time agreements between companies and tax authorities on pricing transactions between group entities. India introduced the system in 2012, in a bid to help stave off drawn-out lawsuits. Nitin Narang, Partner- Transfer Pricing shares his views on Test Ahead for India’s Intercompany Pricing Pacts for Bloomberg BNA- US.
  1. Nitin Narang, Partner- Transfer Pricing shares his views on Test Ahead for India’s Intercompany Pricing Pacts for Bloomberg BNA- US.

Deduction allowed under Section 80PublicationD for preventive check-up only – Chirag Nangia

Rules requiring foreign companies to store certain types of data in India have opened a front in the country’s quest for ways to tax its booming digital economy. The Reserve Bank of India, the central bank, gave financial companies until October to comply with a policy requiring them to store payment data domestically. A draft bill currently being finalized, meanwhile, requires businesses to store at least a copy of personal data they collect on servers in India.

Chirag Nangia, Director answers the weekly queries for DNA readers.

Tax & Regulatory Newsletter – November 16 – 30 ,2018 Edition

Greetings! We are pleased to attach herewith the Tax & Regulatory Newsletter – November 16th- 30th ,2018 Edition highlighting major recent tax and regulatory developments. Inside this issue… DIRECT TAX Ahmedabad ITAT holds that there shall be no disallowance for non-deduction of TDS on an expense till the time such expense is not chargeable to tax Central Board of Direct Taxes notifies 87 jurisdictions for the purpose of defining a ‘passive non-financial entity’ under Section 285BA of the Income-tax Act, 1961 read with Rule 114F of the Income-tax Rules, 1962 Delhi ITAT held that reimbursements of the payments made by the foreign company to personal seconded in India shall be treated as salary and not FTS under Indian tax law EPFO introduces online submission of monthly Form IW-1 Delhi ITAT reiterates the importance of disposal test to qualify as a PE in India; ownership not a pre-condition to constitute PE Madras high Court holds general clause of the agreement cannot determine character of an income to be Royalty or FTS INTERNATIONAL TAX Dutch to tighten tax rules for multinationals after EU pressure Switzerland to end special tax allocation practices for new principal companies, finance branches Google, Facebook Defend Tax Structures To EU Lawmakers U.S. Companies Flee No-Tax Caribbean Havens After EU Crackdown TRANSFER PRICING ITAT consider Taxpayer as a license manufacturer and not contract manufacturer AMP Expense incurred by the manufacturer – not an international transaction, does not warrant separate determination of ALP Determination of Most Appropriate Method as per Section 92C(2) of Income Tax Act, 1961 We trust that you will find it interesting and informative. Nangia & Co LLP_Newsletter_ November 16 – November 30, 2018 Edition

CAs are in a tizzy over SC order on misconduct outside professional sphere – Rakesh Nangia

Dear All Chartered accountants are in a tizzy following a recent Supreme Court order that upheld the right of the regulator to haul them up for misconduct, not related to professional work. This makes any act by a chartered accountant that brings disrepute to the profession, whether or not in the professional domain, open to disciplinary scrutiny and action. Rakesh Nangia, Managing Partner shares his views on aforementioned story for Business Standard.  CAs are in a tizzy over SC order on misconduct outside professional sphere - Rakesh Nangia