TP Blogs
Slump Sale – New Tax Rules – Simplified with example
The Indian tax authorities have strengthened the rules around slump sale transaction
An incentive to AIF – GIFT IFSC
Indian government incentivises AIFs to set up under automatic route in GIFT city and overseas.
Significant Economic presence Test – India Update
5 Financial Advice For Entrepreneurs
Steve Jobs and Sir Richard Branson are my business gurus. They both have touched the epitome of entrepreneurship and have made this world a better place with their respective innovations and enterprising spirit. Yet, their style of entrepreneurship has been poles apart. While one followed an authoritarian way of leadership, Sir Branson followed an inclusive […]
India Equalisation Levy 2.1 (2021 Version)
Whether India Equalisation Levy impacts you
Top Secret to Avoid Transfer Pricing Dispute – Works Every Time
Transfer pricing is an effective tool to allocate profits across the value chain globally so that every tax jurisdiction in the value chain is remunerated with an equitable and fair distribution of taxes. This article is not for the corporations that believe in transfer mispricing and adopts tax avoidance strategies. The beneficiaries of this piece […]
How to Set Transfer Price in Covid – the OECD Way (18 Key Takeaway)
On 18th December 2020, OECD issued a guidance on transfer pricing implications during COVID 19. The guidance is the consensus view of 137 members of the Inclusive Framework of BEPS regarding application of OECD Transfer pricing Guidelines (TPG). The guidance is meant for the taxpayers as well as tax administrations, that would help both of […]
Sharpening the Axe – Transfer Pricing Agreements
Abraham Lincoln quoted as saying “ Give me six hours to chop down a tree and I will spend the first four sharpening the axe. ” An axe is a strength multiplier. You can be the strongest lumberjack in the world, but with a dull axe, you are no good than a 5 year old. In today’s world […]
Transfer Pricing Agreements
A quick walkthrough on Transfer Pricing Inter Corporate Agreements
Top 2 Causes Of Tax Avoidance
This article provides insights in to main broad causes of tax avoidance
Equalisation Levy 2.0
A quick glance in to India’s new equalisation levy – Digital Economy Taxation
Top 6 Transfer Pricing Ideas In Covid 19 – Think Tank For MNCs
Our last blog specifically covered broad level strategies that could be implemented by an MNC due to the business impact that COVID 19 pandemic could have on the global organizations. This blog specifically covers the practical pathways including most relevant points to ponder by the tp management of an MNC (including the CFOs and the […]
5 Key Transfer Pricing Considerations In Covid 19 For MNCs
Gone are the days when a corporation used to limit its activity and operations to a country’s boundary. Businesses are global and see the world as part of the same supply chain. In such a situation, even if there is an issue in one part of the globe the factors of production and demand gets […]
5 Tax Administration Measures In Covid-19 Environment
Tax suggestions for Indian government in COVID 19 situation
Changes In Indian Transfer Pricing Compliance Due Dates – 2020
India Union Budget 2020 has announced certain important date changes in the compliance for Transfer Pricing and Taxation. The change is proposed so that the Income-tax returns/ declarations could carry auto-populated details, which would simplify the tax return form and process. As management or a consultant, you should be geared up and well prepared to […]
Top 5 Transfer Pricing Thoughts To Ponder Over Dividend Tax
This article has a special reference to the amendment made by the India Union Budget 2020 wherein Dividend Distribution Taxation (DDT) was abolished and dividends were made taxable in the hand of the shareholders. The blog tries to act as a think tank to explore any possible transfer pricing implications on such a changed scenario […]
Top 10 Impacts On Investors – Indian Dividend Tax
A quick glance through what would change for an investor with introduction of new dividend taxes
Economic Survey – Summary – India Story – FY 2019-20
The Economic Survey (Survey) of India for the financial year (FY) 2019-20 is out in the public domain today. The Survey is a report card of the Indian economy for the year under consideration and generally forms the basis for building the Union Budget for the next year to come. Such a Survey gives the […]
Make In India @ 15% Tax Cost. Includes Contract Manufacturing
Make in India @ 15% tax cost. Includes Contract Manufacturing
How To Have A Competitive Edge In Business Using Transfer Pricing?
Know how to use transfer pricing tools for daily operational financial decisions
Industry Expectations On The New Direct Tax Code – India
Top 5 industry expectation on the Direct Tax Code 2019
Transfer Pricing And Intangibles – Value Analysis
Intangibles constitute a substantial and major portion of transfer pricing issues on hand. They are extremely crucial in a Multinational (MNE) environment, however, their importance is often undermined to their inherent characteristics which may include easy mobility, misidentification and most importantly non-availability of set principles to assign values to such intellectual properties. Supply Chain and […]
Draft Amendments In Indian Permanent Establishment Rules – Equitable Or Abstract?
Background India has touched upon the taxability of profits of Permanent Establishment (‘PE’) in its international tax treaties under ‘Article 7’. Currently, profits of PE are determined based on its books of accounts considering it as a separate and distinct entity or in case of non-preparation of the same, apportionment is to be done on […]
Drafting A Transfer Pricing Policy
A quick and basic glance on how to draft a transfer pricing policy
What Is Global Transfer Pricing?
Transfer Pricing as a subject means undertaking global international transactions between the related parties (we call it associated enterprises), at a value which is as per the market conditions (Arm’s Length Price), so that the profit allocations between the countries is fair and appropriate. Due to the close relationships, there could be certain influences on […]
The Story Of Interim Budget- 2019
Snapshot of India’s development path The years gone by: With the reforms and positive changes brought about by the current Government, it is truly a golden age for the Indian economy. Ushering in stability in the nation, transformation in all sectors, cleanliness in pecuniary terms by demonetization as well as in literal terms through […]
Angel Tax – Simplifying The Tax Life Of A Start-Up
A lot has been said about angel tax over the years. While the technocrats are well aware of the topic, most of the non-technical start-ups have no clue until they get a surprise from their VC, CA or a tax officer. Let us look at simplifying the topic and understand how some air of confusion […]
Transfer Pricing – Gliding Through The Fundamentals
What is ‘Transfer Pricing’? ‘Transfer Pricing’ is an art and science of determining the value of transactions that take place between entities of the same multi-national group. It involves the consideration of economic factors to perfectly balance a corporation’s and tax authority’s interest in terms of profitability and taxation. Why ‘Transfer Pricing’ in ‘Taxes’? Earlier, […]
Build An Effective Career In Taxes
Till today, I have tried to give my views on the technical side of taxation and hope you have enjoyed. This time, I thought, it is important that the students of commerce, accountancy, finance, law and management understand what the studies in taxation have to offer to them that could give the young minds a […]
Effective Tax Rate – The Mantra To Successful Tax Management
Effective Tax Rate (ETR)
5 Tips For Effective Transfer Pricing Compliance
As the Indian transfer pricing compliance season is around the corner, I am sure, many multinational companies along with the Chartered Accounts would be occupied in justifying and certifying the transfer prices for the company undertaken in FY 2017-18. Here are the top 5 tips for an effective transfer pricing season for the MNC as […]
Top 5 Best Taxation Practices
I have often seen many multinational organizations quoting the increase in top-line figures as an important indicator of growth for a company. Often the management forgets to focus on the bottom line (profits) and something that is below the bottom line (i.e.taxes). While you as an organization is growing at a fantastic pace in terms […]
Is It Compulsory For My Foreign Company To File Income Tax Returns In India…
Taxes are one of the funniest parts of serious business. They are sometimes uncertain, interpretative, dynamic or beneficial to a taxpayer (many more adjectives or attributes could be used). One tax and many forms, often make taxes as one of the complex subjects to understand. Even Albert Einstein laid down his arms before taxes and […]
5 Finance Secrets Making Your Start-Up Attractive
The article provides a glimpse of financial aspects to be taken care while in start-up phase
Intra-Group Service Payments – Tax Risk Mitigation Approach Vs. Tax Litigation Approach
In the globalised world, every multinational enterprise (MNE) would like to work on their strengths to enable efficient and successful supply chain management. In the current scenario, business is not only provision of goods and services to the ultimate external customer, but also provision of such goods and services to the internal customer. In a […]
Critical Analysis – Google India – Adword – Royalty Case
1. The case with regard to the Google AdWord by the Bangalore ITAT could be categorised as a judgement that could have far-reaching effects on the digital economy in India. The judgement and the interpretation of business scenario need to be understood simplistically removing all the technical jargons and marrying the facts of the case […]
“In The Business Of Making Loss” With Special Reference To Taxation Of The Flipkart Deal
The energetic rise of multi-national e-commerce businesses: With the advent of internet a few decades ago, the online marketplace has gained an impetus in recent years, thereby revolutionizing the B2B, B2C and C2C transactions. As a consequence, the hassles of physical limitations, investment of time and boundaries among the nations have been eliminated. Such […]
Tax Avoidance Is Legal- Did You Know That?
When the subject is perceived to be dry, it is imperative to have a catchy headline. In this knowledge bite, we are focusing on the concept of juggled words and meaning between tax planning, evasion, avoidance and the newly coined term ‘Aggressive tax planning’ What is tax evasion? Tax evasion is a complete disregard of […]
3 Facets Of Taxation
In business, there are options, and often decision-makers have a choice to make which decides the fate of the business. Taxation being one of the integral parts of the business have its own option mechanism embedded in it. Taxes could make or break a business. It is up to the business and its driver to prioritize […]
5 Key Points While Filing An Income-Tax Return
Visit: The Indian tax system is a compliance-oriented tax system. Which means, after completion of a financial year, a person who has earned any income (i.e Salary | House Property| Business and Profession | Capital Gains |Other Income), must file an Income-tax return to declare such income and assets. Such a compliance is necessary so […]
10 Tax Administration Principles For Any Tax Economy- Arthashastra
“Arthashahtra” is an ancient Indian thesis on nation’s administration, governance, economic policies including external affairs and military tactics, written by Kautilya, widely acclaimed as “Chanakya”. The treatise date back to 3rd Century B.C, which embeds principles to efficiently administer an economy, which still holds the ground when implemented in modern-day economics. Top 10 principles of taxation that […]
A Cousin In London Wanted Some Mangoes And See What It Led To…!!! (Transfer Pricing Story)
Written and conceptualized by my dear friend Mr. Vishal Thakkar (2014). The principles of the article still hold true, so thought of reblogging. Suresh has a thriving business of exporting agri-products to various countries. His vegetables and fruits are well known amongst a lot of stores in various different countries. His business was doing very […]
A Tax Secret For A Successful Global Business (Start-Ups and MNCs)
Business is anything which is done with a motive of profit. It involves trade, commerce, and adventure. Taxes are paid on profits. It is assumed that the level of profit reflects the true value of the business and therefore, ideally the taxes are collected on the current profits. The tax regulation of a country along […]
Transfer Pricing: A Planning Tool or A Compliance Burden?
When one talks ‘Transfer Pricing’, the first thing that comes to mind is ‘Transfer Pricing Study Report’ or the ‘Documentation’. For many, transfer pricing as a subject revolves around documentation and meeting the compliance timeline, but seldom think of it as an instrument to effectively plan taxes or structure transactions. Through this article, we aim […]
APA In India, A Potential Tax Risk Management Tool
MNEs think of transfer pricing as the major tax challenge in India. They face numerous audits and court cases on this topic. A new development is that India seems to have embraced the Advanced Pricing Agreement as a tool to discuss and agree on the at arm’s length remuneration upfront. As the name suggests, these agreements […]
Secondary Adjustments – An Operational Reality
Secondary adjustments – An operational reality In generic sense, anything secondary has often been thought as a by-product or addition. Although it can a spin-off from a primary factor, essentially inheriting its qualities, it often looks to embellish an already painted landscape. In India’s case, the landscape of transfer pricing litigation has always been dynamic, […]
Safe Harbour – Intra Group Services
Revised Safe Harbour Rules notifies “Low Value-adding intra-group services” – No transfer pricing documentation up to INR 10 crores Globally service-oriented transactions account for more than 60% share in international trade. Service often classified as intangible in nature, is hard to evaluate and measure from a transaction perspective. This means, intangible benefits enjoyed by the […]