BEPS Impact assessment
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BEPS Impact assessment - Imperative for Indian and Foreign MNCs. Changes in international taxation rules post OECD BEPS action plan are inevitable. It is important that your organization is prepared for such changes. We therefore recommend a review of existing structures to evaluate potential tax risks that can be addressed.
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Solution of Assessment 2Change Management Plan 1.I.docx
Solution
of Assessment 2
Change Management Plan
1.
Introduction
Instructions: In 200 words,
Write about the background of Australian Rural Development Bank(ARDB) and explain about its organizational objectives, policies, and practices.
Also write why or how the board of ARDB came with the decision to introduce organizational changes. (Read the first para of Assessment 2 scenario)
In background you may include ‘When was the bank established? When did it receive banking license? What are the objectives of the bank? Please note that this is RURAL DEVELOPMENT BANK. Understand the functions of a rural development bank first. Where is its headquarters located (say Sydney)? How many branches are there? What products or services do the bank offer? What policies (e.g. Related to operations, loans, lending, finances, etc.) are developed in the bank and what kind of banking practices do the bank follow?
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In the second part, mention the problems in the bank and explain that to overcome these problems and improve the performance of the organization, the CEO or the board members of the bank want to bring organizational changes. Explain what your role and your tasks in the last line.
2.
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2.1
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Instructions: In 100 words, explain the drivers or factors or reasons that pushes the board of the ARDB to decide on bringing the organizational changes. In short why they want to bring the changes. List the drivers for changes and explain them in brief.
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2.2
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Instructions: In 50 words explain the constraints of the changes. Do not confuse it with barriers for changes. Constraints mean limitations related to the organizational changes here. You can talk about three constraints.
Time constraints: How much time do you have to plan and implement the changes?
Cost constraints: How much budget is allocated for the planning and implementation?(This may be related to cost benefit analysis in topic 6)
Scope: Where will the changes apply?
3.
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Instructions: Explain what changes are required in the organization. Please note that these changes should solve the problems of the Australian Rural Development Bank as mentioned in the first para of the assessment 2.
Read the assessment scenario and the types and examples of changes. What are the main elements in the change plan? [E.g. people/culture, systems/technology, documentation, positions/roles, process, skills] Each of these elements may require a focus in the change plan.
S. No.
Problems
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Solution
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Change Management Plan
1.
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Instructions: In 200 words,
Write about the background of Australian Rural Development Bank(ARDB) and explain about its organizational objectives, policies, and practices.
Also write why or how the board of ARDB came with the decision to introduce organizational changes. (Read the first para of Assessment 2 scenario)
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https://www.finanssiala.fi/en/material/Good-Banking-Practice-2015.pdf
In the second part, mention the problems in the bank and explain that to overcome these problems and improve the performance of the organization, the CEO or the board members of the bank want to bring organizational changes. Explain what your role and your tasks in the last line.
2.
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2.1
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Instructions: In 100 words, explain the drivers or factors or reasons that pushes the board of the ARDB to decide on bringing the organizational changes. In short why they want to bring the changes. List the drivers for changes and explain them in brief.
Some of the drivers for organizational changes are given in the link below. Explain the drivers that are relevant to ARDB
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2.2
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Organizational changes
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Dear Members,
We are pleased to present to you ‘TransPrice Times – July 2018 edition’.
This periodical covers key court rulings on selection of different tested party; FAR analysis and Rule of consistency.
Apart from this, recent news relating to the draft e-commerce policy released by Government of India have been discussed in the periodical. Links to the OECD’s recent activity and our Special Edition article on ‘Changing Colours of Indian Tax Audit (3CD)’ have also been cited.
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TransPrice Times - 16th - 28th February 2018
Dear Members,
We are pleased to present to you ‘TransPrice Times – edition 16th - 28th February 2018’.
This periodical covers key court rulings on Transfer Pricing documentation, attribution of income to a permanent establishment; and advertising, marketing & promotion expenses. Apart from this, recent news relating to Advance Pricing Agreements and OECD updated guidance on Country-by-Country Reporting have been discussed in the periodical.
Thank You and Happy Reading!!
TransPrice Times - 16th January 2018 - 15th February 2018
Dear Members,
We are pleased to present to you ‘TransPrice Times – edition 16th January 2018 to 15th February 2018’.
This periodical covers key rulings relating to treaty benefits on capital gains under the India-Mauritius tax treaty and issues relating to related party transactions forming part of a transfer pricing study.
We would be happy to know your suggestions. You can write to us at akshaykenkre@transprice.in
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Apart from this, recent news on implementation of BEPS measures in the India-China tax treaty has been highlighted in the periodical.
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Thanks a lot.
TransPrice Times - 16th December 2017 - 15th January 2018
Dear Members,
We are pleased to present to you ‘TransPrice Times – edition 16th December 2017 to 15th January 2018’.
This periodical covers key court rulings on determination of entities as ‘Associated Enterprises’; specified domestic transactions; sale of shares; reimbursement of expenses and nature of expenses.
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TransPrice Times - 1st - 15th December 2017
Dear Members,
We are pleased to present TransPrice Times for the first fortnight of December 2017.
This periodical covers key court rulings on the right to use multiple year data, foreign exchange gain / loss, segregation of interlinked business activity in transfer pricing, and outstanding receivables from related party. Apart from this, recent news relating to OECD's 2017 Model Tax Convention, which are commentaries of tax treaties including BEPS changes, has been discussed in the periodical.
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TransPrice Times - October & November 2017
Dear Members,
We are pleased to present TransPrice Times for the month of October & November 2017.
This periodical covers key court rulings on the issues of entity level approach over transactional approach, treaty benefits, receivables from an associated enterprise, royalty & TDS provisions, and real income theory. Apart from this, recent news relating to India's stand on MAP and bilateral APA applications has been discussed in the periodical.
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TransPrice Times 16th - 31st August 2017
Dear Members,
We are pleased to present TransPrice Times for Second fortnight of the month of August 2017.
This periodical broadly covers important rulings, addressing different key issues pertaining to foreign exchange gain as operating revenue, transfer pricing adjustment on non-utilization of agreed services and determination of most appropriate methods in transfer pricing.
We would be happy to know your suggestions. You can write to us at akshaykenkre@transprice.in
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TransPrice Times - 1st - 15th August 2017
Dear Members,
We are pleased to present TransPrice Times for first fortnight of the month of August 2017.
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TransPrice Times - July 2017
Dear Members,
We are pleased to present TransPrice Times for the month of July 2017.
This periodical broadly covers important rulings, addressing different key issues pertaining to transfer pricing methods and fair assessment proceedings. With CBDT notifying form for opting the revised safe harbour rules and OECD continually coming out with new clarifications, the international tax world is buzzing with the news flutter around CbC Report and multilateral agreement, which we have covered in this periodical.
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TransPrice Times 16th - 30th June 2017
Dear Members,
We are pleased to present TransPrice Times for the second fortnight of June 2017.
This periodical broadly covers important rulings, addressing different key transfer pricing issues related to treatment of royalties received from an Indian company & foreign company's viewpoint, and service PE.
TransPrice Times - Summarising Multilateral Instruments
Dear Members,
We are pleased to present TransPrice Times - Summarising Multialteral Instruments (MLI) for June 2017.
June 7 2017 was no ordinary day for the tax world. OECD initiated the historic signing process of the multilateral instrument agreement which involved the participation of 68 countries including India.
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We would be happy to know your suggestions. You can write to us at akshaykenkre@transprice.in
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New Safe Harbour Rules
Dear Members,
We are pleased to present a snapshot of transfer pricing Safe Harbour Rules notified today vide CBDT Notification 46 of 2017. Margins rationalized and includes "low value adding intra-group services"
We would be happy to know your suggestion. You can write to us at akshaykenkre@transprice.in
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TransPrice Times - 16th - 31st May 2017
Dear Members,
We are pleased to present TransPrice Times for the second fortnight of May 2017.
This periodical covers important rulings, addressing key transfer pricing issues related to adhoc adjustments, payment of management fees, risk adjustment and AMP adjustment. Further, in the backdrop of constant dynamism on the international taxation front, OECD has recently released a discussion draft on Hard-To-Value-Intangibles which has been covered in this periodical.
TransPrice Times 16th - 30th April 2017
Dear Members,
We are pleased to present TransPrice Times for the second fortnight of April 2017.
Issues on permanent establishments, brand development, deemed international transactions and royalty payments are discussed in this periodical.
TransPrice Times 1st - 15th April 2017
Dear Members,
We are pleased to present TransPrice Times for the first fortnight of April 2017.
This periodical covers some key aspects from transfer pricing and international taxation, including rulings on foreign tax credit, royalties, benefit test and withholding taxes. For all the innovators, it is important to note the release of Form No. 3CFA for obtaining tax relief under patent box regime under S. 115BBF of the Income-tax Act 1961.
We would be happy to know your suggestions. You can write to us at akshaykenkre@transprice.in
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