Comparable Uncontrolled Price Method Transfer Pricing

Comparable Uncontrolled Price Method

Comparable Uncontrolled Price Method Transfer Pricing The application of Arm’s Length Principle while implementing the provisions of Transfer Pricing, to arrive at the price of a transaction between unrelated parties is essential. However different situations call for application of different methods of the ALP principle, depending on the mitigating factors in every transaction. One such … Read more

Article 2 – Taxes covered under Double Taxation Avoidance Agreement ?

Taxes covered under Double Taxation Avoidance Agreement

Article 2 – Taxes covered under Double Taxation Avoidance Agreement This Article provides the details of taxes, which would be covered for the purpose of tax Treaty.   Any tax which is not provided in Article 2 is outside the purview of the tax Treaty. Article 2 defines the taxes, to which the Treaty shall apply. … Read more

What is International Tax Law

What is International Tax Law? International tax law , in the context of taxation , are the  laws, which apply to tax income from activities, that takes place in two or more countries. International tax law, can be found in either of the following : – International Tax Agreements – What are International Tax Agreements … Read more

Business Acquisition in India – Share Purchase Vs. Acquisition of Business

BUSINESS ACQUISITION – SHOULD I PURCHASE SHARES OF INDIAN COMPANY OR ACQUIRE ASSETS ?

When making a business acquisition in India, a foreign Investor needs to take a decision on whether it should purchase the shares of the target company, or  it should acquire the business as a whole (other modes of acquisition like acquiring assets  on a piecemeal basis/through reverse merger into acquirer entity are not covered in this Article). … Read more

Section 9A – Taxation of Offshore Funds in India

SECTION 9A TAX ON OFFSHORE FUNDS IN INDIA

Bird’s Eye view of the ‘Taxation of offshore funds in India’ Concept of taxation Non-Resident Taxation Provision of Income Tax Act, 1961 Section 9A Provision deals with Taxation of offshore funds in India Section 9A Tax on Offshore Funds India is important for overseas mutual funds that invest in Indian equities, debt and other instruments. … Read more

What is Foreign Direct investment in India?

Foreign Direct Investment in India - FDI India

Foreign Direct Investment in India or FDI in India as it is commonly called, refers to investment in Indian companies by non-residents. Foreign Direct Investment (FDI) is considered as a major source of non-debt financial resource for economic development of a nation. There are various aspects involved in Foreign Direct Investment in India, and understanding … Read more

International Taxation Case Studies

International Taxation Case Studies

International Taxation Case Studies –  Transfer Pricing and Non Resident Taxation – by CA Arinjay Jain International Taxation Case Studies, which can be accessed from the links below, are in respect of certain practical situations, that arise during the course of conducting international business. The case studies have been prepared keeping in mind, the existing … Read more

Interest paid by a Foreign Bank Branch to overseas HO and other Branch – Non Resident Taxation

Interest paid by a Foreign Bank Branch to overseas HO and other Branch

Interest paid by a Foreign Bank Branch to overseas HO and other Branch – Non Resident Taxation – International Taxation Case Study LLM Bank Ltd. carrying on banking business is incorporated in Melbourne, Australia. It has branches in different countries including India. During   financial year 2018-19, the Indian branch of the bank paid interest of … Read more

NRI returning to India and continuing to have overseas income

NRI returning to India and continuing to have overseas income

NRI returning to India and continuing to have overseas income – International Taxation Case Study Peeyush, a Non-Resident Indian returned to India on 12th June, 2018 for permanently residing in India after a stay of about 20 years in U.K., provides the sources of his various income and seeks your opinion to know about his … Read more

Learn  International Tax Course +  Live Webinars, Polls, Case studies and Seek answers —  Join our Community now – 30 days Free Trial!

INTERNATIONAL 
TAX COURSES+COMMUNITY

Join our vibrant International Tax Community to Learn International Tax Course, Interact with fellow members, Live Webinars, Polls, Case studies and Seeking answers —your all-in-one hub for networking and staying updated!

INTERNATIONAL
TAX COURSES+COMMUNITY

Join our vibrant International Tax Community to Learn International Tax Course, Interact with fellow members, Live Webinars, Polls, Case studies and Seeking answers —your all-in-one hub for networking and staying updated!