Arm’s Length Price
Arm’s length Principle – The ARM’s length principle is the fundamental principle within Transfer Pricing. The purpose of this principle is that where there is
August 14, 2018
No Comments
Category: CA Final International Taxation
Deemed Associated Enterprises – Section 92a(2) – Common Individual Control In Two Enterprise
Where one enterprise is controlled by an individual, the other enterprise is also controlled by such individual, or his relative, or jointly by such individual
August 14, 2018
No Comments
Deemed International Transaction
Deemed International Transaction in Transfer Pricing [Section 92B] (2) A transaction shall be treated as deemed international transaction entered into between two AEs, even though
August 14, 2018
No Comments
August 1, 2018
No Comments
Section 172 – Assessment /collection of tax of non-resident in shipping business
A) APPLICABILITY : – The provisions of this section shall apply for the purpose of levy and recovery of tax in case of shipping business of
August 1, 2018
No Comments
Zero Coupon Bonds – Cost of acquisition in case of Global Depository Receipts
ZERO COUPON BOND (ZCB) – SECTION 2(48) Zero coupon bond means a Bond issued by any infrastructure capital company or infrastructure capital fund or a
August 1, 2018
No Comments
Black Money Act – Undisclosed Foreign Income and Asset Act
RELEVANT PREVIOUS YEAR FOR CHARGEABILITY TO TAX – UNDISCLOSED FOREIGN INCOME – SECTION 3 The provisions of the Black Money Act are effective prospectively from
August 1, 2018
No Comments
Controlled Foreign Corporation (CFC) Rules and Thin capitalization – BEPS
In certain cases, taxpayers who have controlling interest in a foreign subsidiary, can use intermediary companies (referred to as a “Controlled Foreign Corporation” or
August 1, 2018
No Comments
Double Taxation Relief in India and Foreign Tax Credit
AGREEMENT WITH FOREIGN COUNTRIES OR SPECIFIED TERRITORIES – BILATERAL RELIEF – SECTION 90 (1) Central Government may enter into an agreement, with the
August 1, 2018
No Comments
MCQ – CA Final Elective 6C International Tax
1) Source rule of taxation provides that income is to be taxed :- a. In the country of residence of taxpayer b. In the country
July 31, 2018
No Comments
Advance Pricing Agreement
WHAT IS ADVANCE PRICING AGREEMENT (APA) ? a) An ADVANCE PRICING AGREEMENT (APA) is an agreement between a tax payer/applicant and the CBDT, i) which
July 31, 2018
No Comments
Safe Harbour Rules
Safe Harbour Rules – In this Article, we would discuss about Safe Harbour Rules under the Indian Transfer Pricing Regulations. Transfer Pricing involves lot of
July 29, 2018
No Comments