Category: CA Final International Taxation

APPLICABILITY OF MAT ON FOREIGN COMPANIES – SECTION 115JB Under the provision of the Income Tax Act, where the tax payable by the company as

RESIDENTIAL STATUS OF A HUF, FIRM, AOP/BOI, LOCAL AUTHORITIES AND ARTIFICIAL JURIDICAL PERSONS Residential Status of HUF – An HUF, Firm, AOP/BOI, local authorities and

RESIDENTIAL STATUS OF AN INDIVIDUAL – CRITERIA FOR DETERMINING WHETHER A PERSON IS A RESIDENT IN INDIA As per Section 6(1), an individual,  is said

Introduction to Non-Resident Taxation Taxation of non-residents in any country,  in respect of Cross – Border transactions, can be taxed  based on the following criteria

FOR UNDER-REPORTING OF INCOME – SECTION 270A Section 270A provides for levy of penalty @ 50% of tax payable (including surcharge and education cess), for

FUNCTIONAL ANALYSIS FOR EVERY INTERNATIONAL TRANSACTION, THE COMPANY NEEDS TO UNDERTAKE A FUNCTIONAL ANALYSIS AS UNDER DIAGRAM 1.53 For every international transaction, Functional, Asset and

Documents and Compliances – Documentation required under the income tax act 1961 ASSESEE UNDERTAKING AN INTERNATIONAL TRANACTION Under the Indian Transfer Pricing regulations, where an

FUNCTIONS, ASSETS AND RISK (FAR) ANALYSIS DIAGRAM 1.49 Functions, Assets and Risk (‘FAR’) analysis,  is the method of finding and organizing facts about the business

CBDT  has prescribed the ‘Other Method’ Transfer Pricing by inserting Rule 10AB to the Income-Tax Rules. For determination of arm’s length price in relation to

Under Transactional Net Margin Method (TNMM), a comparison is made for the operating profit derived by tested party,  from a controlled transaction, relative to an

Transfer Pricing provisions are applicable to determine the arm’s length price of ‘International transaction’ and ‘Specified domestic transactions” between Associated enterprises. Even though domestic transactions