Company engaged in operations of Aircraft – Non Resident Taxation – International Taxation Case Study GetSetGo  Airways is engaged in operation of aircraft and leased  certain   aircraft from Goeing UK. During the year, the various payment made by GetSetGo  Airways to Goeing UK, were as under : – Nature Amount Tax on Income Total Payment … Read more

Corporate restructuring overseas – Non Resident Taxation – International Taxation Case Study Sunio Japan, is a global company, which has subsidiaries in various countries. Five of its subsidiaries , hold 100% share capital of Sunio India, which were acquired by them at various cost over the years. The group undertook Corporate restructurings in FY 2018-19, … Read more

Adjustment and Scope of Assessment – Advance Pricing Agreement – Transfer Pricing – International Taxation Case Study AB India Private Limited was incorporated under Companies Act, 2013, at Mumbai, and is a subsidiary of USA based company AB Inc. It is engaged in providing asset management software, namely, OPAC, to Indian clients. Such software can … Read more

Presumptive taxation Transfer Pricing – International Taxation Case Study GGC & CO. is a reputed firm of Chartered Accountant in Gurgaon, dealing in Audit, Direct Taxation, GST, Merger and Acquisition and cross-border taxation, etc. Following clients approached such firm for computation of their income-tax liability and filing of their income-tax return Mr. A engaged in … Read more

Income deemed to accrue or arise in India – Transfer Pricing – International Taxation Case Study Mr. Amar is working as a tax advisor for a law firm based in Lajpat Nagar, Delhi.  He has two sons, namely, Akbar and Anthony who both went to Country X in 2010 after completing their LLM from Netherlands … Read more

Applicability of Transfer Pricing and Base Erosion – International Taxation Case Study Identify whether transfer pricing provisions would be applicable on the following transactions : – Interest free loan given to the Indian company by its parent Interest free loan given by the Indian company to its wholly owned subsidiary in Japan Free laptops provided … Read more

Notified Jurisdictional Area Transfer Pricing – International Taxation Case Study CBDT has notified Country A as NJA u/s 94A on April 01, 2017 due to lack of effective exchange of tax information with India. On August 01, 2017,  X Ltd.  has received a loan of Rs. 10,00,000 @10% per annum from  Y LLC.,   who is … Read more

Advance Pricing Agreement (APA) Transfer Pricing – International Taxation Case Study Identify which of the APA can be entered into in the following cases : – Particulars Country A Country B Country C Indian Treaty Yes No Yes Relevant MAP Article 25 NA – However, Country B – USA Treaty has a MAP Article No … Read more

Cost Plus Method Transfer Pricing – International Taxation Case Study Doorlock India is a company incorporated under the Companies Act, 2013, a wholly owned subsidiary of Doorlock USA, and has  a factory   in Haryana. It is engaged in manufacture of door locks , door handle and other security product. Amongst several other products, the company … Read more

Secondary Adjustment Transfer Pricing – International Taxation Case Study Gama Ltd., an Indian company, has provided you the following information for year ended 31.3.2019 : –  Transaction Related Enterprise Amount as per Invoice (Rs. in crores) Amount as per ITR Purchase of raw-materials Gama  , China 200 180 Payment of royalty Gama  Pty Singapore 100 … Read more