How to tackle a doubled increase in withholding taxes to 20% on Royalties and FTS?
The Finance Bill 2023 that the Indian parliament passed increased the withholding tax rate under the Income-tax Act, 1961 for payment of Royalties and Fees for Technical Services (FTS) paid to non-residents from 10% to 20%. India is a net importer of technology and high-end services from foreign jurisdictions. In such cases, Indian multinational pays […]
Transfer Pricing in recession times.
The process of arriving at the fair value of products and services exchanged between connected organisations within a multinational corporation is known as transfer pricing (MNC). The significance of transfer pricing increases during recessions as companies try to manage their tax liabilities and maximise their cash flows. This blog post will examine how MNCs might […]
Angel tax comes back to open up Pandora’s box in transfer pricing.
Published in Taxsutra.com on 07 February 2023 by Akshay Kenkre and Mit gaglani The Union Budget 2023 widens the applicability of angel tax to investments from foreign investors. Such an amendment could have a far-reaching impact on reversing the landmark transfer pricing ruling by the Bombay High Court in the case of Vodafone India Services […]
Top 10 Union Budget expectations on Indian transfer pricing
Transfer pricing regulations can affect how multinational companies (MNCs) do business in several ways. Regarding the Indian way of undertaking transfer pricing, the tune changes slightly compared to the globally established principles. The law has evolved over the past 21 years. Today, enough clarity and jurisprudence are available in the public domain for the management […]
How to defend Intra-Group service payments in transfer pricing?
Intra-group services are provided between the Multinational Enterprise (MNE) members. These services can be of any sort, for instance, services related to IT, Human resources, Marketing, Legal, Accounting and administration, Technical Services, Quality control services, and Other services like research and development, corporate security, logistics, etc. While an MNE looks at itself as one unit, […]
The Curious case of taxing Virtual Digital Assets (Cryptocurrencies) in India
Has Akbar found his Birbal yet for valuing the invaluable? Once upon a time, the great Akbar asked one of his intelligent ministers, Birbal, to resolve a case where the issue was a valuation of food aroma stolen by a person from a sweet shop. Birbal was in doubt as to how something could be […]
UAE adopts Transfer Pricing Regulations
One of the biggest global events of 2023 will be the advent of the Income-tax regime in the United Arab Emirates. UAE has officially issued a federal decree-law on corporate tax at a 9 per cent rate for taxable business profits exceeding AED375,000. Federal Decree-Law No. 47 of 2022 on Taxation of Corporations and Businesses (the “Corporate […]
India to gain from Mauritius- Hong Kong Tax deal
It’s official: A Double Tax Avoidance Agreement, commonly known as a tax treaty, was signed by Mauritius and Hong Kong in early November 2022. Hong Kong-based funds investing in India do not enjoy any tax concessions on the source income generated in India (for example, interests and dividends). On the contrary, the treaty with Mauritius […]
Top 10 Reasons why India is the world’s most attractive Investment Destination
From one of the oldest civilisations in the world to one of the most adaptive and modern societies, the journey of Indian economics has been fascinating. The economic studies in the form of Arthashatra were born right here. The principles of governance, administration and taxation of a state, explained in the manuscripts of Arthashashtra, still […]
After LIBOR, What next?
About LIBOR LIBOR (the London Interbank Offer Rate) is administered by the Intercontinental Exchange (ICE) and regulated by the UK Financial Conduct Authority (FCA). It had been computed daily in London for five currencies each with seven different maturities ranging from overnight to a year. The five currencies for which LIBOR is computed are Swiss […]