Please find attached 'TransPrice Weekly' for the forth week of March 2014.
The Snippet covers news alert on approval of first Advance Pricing Agreements and Bombay High Court's decision on commission payouts.
Trust you will find it useful.
TransPrice presents to you TransPrice Times for October 2014.
The snippet includes recent happenings in the transfer pricing world including the landmark judgement in the case of Vodafone and Mitsubishi (Japanese Sogo Shosha Companies). Trust you will find it useful. Happy reading !!!
Composition Scheme in Revised GST Model Law
Eligibility & Conditions for Composition Scheme in GST Law
Rate of Tax in Composition Scheme
Restrictions to opt Composition Scheme
Return Form & Due dates in Composition Scheme
Late fees
This document provides an overview of value added tax (VAT) including:
1. VAT is an indirect tax assessed on the value added to goods and services at each stage of production and distribution. Over 130 countries have introduced VAT.
2. VAT was introduced in India in 2005 and is administered by the government revenue authority. It is a multi-stage tax collected fractionally at each stage of production/distribution.
3. Advantages of VAT include increased tax base and revenue, transparency, avoidance of double taxation, coordination with income tax, and simplification compared to other tax systems.
Composition Scheme under the Goods and service tax ACTYogesh Nain
Background of Composition Scheme under the GST
Definition under the GST
Eligibility under the GST
Rates of Composition Scheme Dealer
How to Make a Registration and how to file the returns.
Important Definitions
Practical’s Solutions how to file the Composition Scheme Returns
The document discusses key aspects of the GST framework including the taxable event, meaning of supply, exclusions, and exemptions.
1) Under GST, the single taxable event of "supply" replaces multiple taxable events such as manufacture, provision of service, and sale that were prevalent in earlier indirect tax regimes.
2) The definition of "supply" is very broad and inclusive, intended to expand the scope of taxation. It includes various transactions like barter, imports, supplies without consideration. This broad definition may lead to unintended taxation and litigation.
3) The document examines exclusions from the definition of "taxable person" as well as the power of the central and state governments to
This document discusses key concepts related to Value Added Tax (VAT) in India, including:
1) VAT is a tax on the sale or purchase of goods levied by state governments based on constitutional powers. It aims to reduce cascading of taxes.
2) The key benefit of VAT over the previous sales tax system is the input tax credit mechanism, which allows traders to deduct taxes paid on previous purchases/inputs from their total tax liability on sales.
3) VAT applies at multiple stages of production and distribution, with tax charged on value added at each stage and cross-credits of taxes paid allowed through the input tax credit mechanism. This avoids double taxation.
Ravinder Kumar is a Chartered Accountant with over 7 years of experience in taxation compliance and accounting. He has expertise in income tax, GST, excise duty, and VAT compliance. Currently he works as a Deputy Manager of Taxation at Fena Private Limited, an FMCG company, where he is responsible for tax compliance, returns filing, and liaising with tax authorities. Previously he worked as Assistant Manager of Accounts and Taxation at HPL Electric & Power, where he handled taxation, accounting, and internal/statutory audit responsibilities. He is proficient in SAP, MS Office, and Tally.
TransPrice presents to you TransPrice Times for October 2014.
The snippet includes recent happenings in the transfer pricing world including the landmark judgement in the case of Vodafone and Mitsubishi (Japanese Sogo Shosha Companies). Trust you will find it useful. Happy reading !!!
Composition Scheme in Revised GST Model Law
Eligibility & Conditions for Composition Scheme in GST Law
Rate of Tax in Composition Scheme
Restrictions to opt Composition Scheme
Return Form & Due dates in Composition Scheme
Late fees
This document provides an overview of value added tax (VAT) including:
1. VAT is an indirect tax assessed on the value added to goods and services at each stage of production and distribution. Over 130 countries have introduced VAT.
2. VAT was introduced in India in 2005 and is administered by the government revenue authority. It is a multi-stage tax collected fractionally at each stage of production/distribution.
3. Advantages of VAT include increased tax base and revenue, transparency, avoidance of double taxation, coordination with income tax, and simplification compared to other tax systems.
Composition Scheme under the Goods and service tax ACTYogesh Nain
Background of Composition Scheme under the GST
Definition under the GST
Eligibility under the GST
Rates of Composition Scheme Dealer
How to Make a Registration and how to file the returns.
Important Definitions
Practical’s Solutions how to file the Composition Scheme Returns
The document discusses key aspects of the GST framework including the taxable event, meaning of supply, exclusions, and exemptions.
1) Under GST, the single taxable event of "supply" replaces multiple taxable events such as manufacture, provision of service, and sale that were prevalent in earlier indirect tax regimes.
2) The definition of "supply" is very broad and inclusive, intended to expand the scope of taxation. It includes various transactions like barter, imports, supplies without consideration. This broad definition may lead to unintended taxation and litigation.
3) The document examines exclusions from the definition of "taxable person" as well as the power of the central and state governments to
This document discusses key concepts related to Value Added Tax (VAT) in India, including:
1) VAT is a tax on the sale or purchase of goods levied by state governments based on constitutional powers. It aims to reduce cascading of taxes.
2) The key benefit of VAT over the previous sales tax system is the input tax credit mechanism, which allows traders to deduct taxes paid on previous purchases/inputs from their total tax liability on sales.
3) VAT applies at multiple stages of production and distribution, with tax charged on value added at each stage and cross-credits of taxes paid allowed through the input tax credit mechanism. This avoids double taxation.
Ravinder Kumar is a Chartered Accountant with over 7 years of experience in taxation compliance and accounting. He has expertise in income tax, GST, excise duty, and VAT compliance. Currently he works as a Deputy Manager of Taxation at Fena Private Limited, an FMCG company, where he is responsible for tax compliance, returns filing, and liaising with tax authorities. Previously he worked as Assistant Manager of Accounts and Taxation at HPL Electric & Power, where he handled taxation, accounting, and internal/statutory audit responsibilities. He is proficient in SAP, MS Office, and Tally.
Basic tenets of GST - Dr Sanjiv Agarwal - Article published in Business Advisor, dated May 10, 2016 - http://www.magzter.com/IN/Shrinikethan/Business-Advisor/Business/
Tweeted on www.twitter.com/BusinessAdvDM #BusinessAdvisorArchives
The document discusses Goods and Services Tax (GST) composition scheme in India, which provides a simplified tax structure for small taxpayers. Key points include:
1) The composition scheme is optional for taxpayers with annual turnover up to Rs. 50 lakhs and requires paying a flat rate of tax instead of filing regular returns.
2) Taxpayers in the composition scheme pay taxes quarterly at rates between 1-5% depending on the business and file simplified annual returns.
3) Businesses can exit the composition scheme if their turnover exceeds limits or if they are no longer eligible, and must then start filing regular returns and claiming input tax credits.
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.
Thank You and Happy Reading!!
The document provides an overview of recent changes to tax compliance requirements in India. It discusses updates to income tax laws under the Finance Bill of 2017, including a reduced corporate tax rate for small businesses. It also outlines the key compliance obligations under the upcoming Goods and Services Tax (GST) such as registration requirements, tax return filing, and transitional provisions to carry forward existing tax credits under the new system. Finally, the document presents a chart summarizing the frequency of various compliance filings like TDS returns, VAT returns, and secretarial obligations.
The document discusses the preparedness required by the textile industry for implementing GST by July 1st, 2017. It outlines the indicated GST rates for various textile products and provides 21 steps that the textile industry needs to take immediately, such as taking stock of raw materials and finished goods, finalizing software and invoice/order formats, updating supplier details, and understanding return filing requirements. It also notes that in July 2017, the GST rate on merchant services was sharply cut to 5% from 18% for textile manufacturers.
The document discusses Goods and Service Tax (GST) in India. It introduces GST as an indirect tax implemented on July 1, 2017 that replaced several other taxes including sales tax, central sales tax, service tax, and central excise. GST is made up of four types - IGST, SGST, CGST, and Cess. Goods and services are taxed under GST at rates of 0%, 3%, 5%, 12%, 18%, or 28% and small dealers have the option to use a composition scheme with turnover up to 75 lacs.
This document discusses India's Goods and Services Tax (GST) composition scheme. It provides:
1) An overview of the composition scheme, which allows eligible small businesses to pay tax at 1% of their annual turnover in lieu of regular tax.
2) Eligibility requirements to opt for the composition scheme, including an annual turnover limit of 50 lakhs.
3) Conditions for opting into the scheme, such as restrictions on inter-state supplies and inability to claim input tax credits.
This edition of TransPrice Times provides you with highlights on recently introduced APA roll back rules along with other updates in Transfer Pricing for the first fortnight of March 2015.
The document summarizes the impact of GST on the textile industry in India. Some key points:
- Under GST, taxes like excise duty, VAT, CST etc. will be subsumed and replaced by CGST, SGST and IGST which will remove cascading of taxes and improve input tax credit flow.
- Overall tax incidence on textiles is expected to increase slightly due to higher GST rates compared to previous taxes. This may impact product mix in the industry.
- Compliance burden is also expected to increase initially due to transition challenges but compliance overall will improve in the long run.
- Inter-state trade barriers will be removed, improving competition and organized
The document summarizes key provisions of the composition scheme under the Revised Model GST Law. Taxpayers with an aggregate turnover of less than Rs. 50 lakhs (Rs. 10 lakhs for North Eastern states) can opt for paying GST at a fixed percentage on turnover instead of the regular tax. They will file quarterly returns instead of monthly and are not eligible for input tax credits. The composition scheme is beneficial for small businesses where the input tax rate is low.
Like Central Government, State Governments also make changes in taxes covered in their fold. One major tax collected by States is VAT. Following the footprints of Center, States also make lots of changes under their VAT Act. It is difficult and crucial to get along with the changes proposed in all State VAT Acts. Hence, after hours of research, we have summarised the changes made by States in their VAT Act till date. We have also included reasons contributing to such change at relevant places.
This document provides an introduction and overview of India's GST composition scheme. Key points include:
- The composition scheme is a simple alternative for small taxpayers with turnover less than Rs. 1.5 crore to pay GST at a fixed rate instead of going through regular GST procedures.
- As of 2019, service providers can now opt for the composition scheme if their turnover is below Rs. 50 lakhs.
- To be eligible, total turnover from all businesses with the same PAN must be below Rs. 1.5 crore, and some business types like manufacturers of specific goods are excluded.
- Opting for the composition scheme means no input tax credit can be claimed but
- Value Added Tax (VAT) is calculated as the difference between tax paid on sales and tax paid/payable on purchases within West Bengal during a tax period. It provides a set-off for tax paid on inputs against tax payable on outputs.
- Under VAT, existing dealers and new dealers exceeding certain turnover thresholds must register and pay VAT. All registered dealers are given an 11-digit Taxpayer Identification Number (TIN).
- VAT rates range from 1% to 12.5% for most goods. Exports and sales to special economic zones are zero-rated while some goods are exempted. Dealers have options to pay compounded rates in some cases.
This document provides an overview of the Goods and Service Tax (GST) system that will be implemented in India. It states that GST is a destination-based tax on the consumption of goods and services. It will replace many existing taxes levied by the central and state governments. The document outlines the key features of GST, including what will be taxed, the types of GST (CGST, SGST, IGST), invoice requirements, input tax credit rules, registration requirements, and transitional provisions for existing taxpayers. It concludes by listing several actions businesses need to take to prepare for GST implementation, such as classifying items and updating vendor/customer information.
Composition levy GST ( Composition Scheme GST )CA-Amit
Only taxable persons whose ‘aggregate turnover’ does not exceed Rs. 50 lacs in a financial year will be eligible to opt for payment of tax under the composition scheme.As per Section 16, Goods and/or services on which composition tax has been paid under Section 8 is not eligible for input tax credit.
GST is a comprehensive indirect tax levied on supply of goods and services. India has adopted a dual GST model where both central and state governments can levy GST. Key points include that GST will subsume most indirect taxes, exceptions include alcohol, petroleum and real estate. Registration is required if annual turnover exceeds Rs. 25 lakhs and involves obtaining a 15-digit GST identification number. The document provides details on registration procedures, compounding, exceptions and migration of existing taxpayers to GST.
This document provides an overview of input tax credit (ITC) under the Goods and Services Tax (GST) regime in India. It defines key terms related to ITC such as input, capital goods, input tax, output tax, and reverse charge. It outlines the conditions for claiming ITC and lists items for which ITC is ineligible. It also discusses proportionate credit, adjustments to ITC, transition provisions for claiming ITC on stock, and the process for claiming ITC on inter-state and intra-state supplies.
Ppt on Composition Scheme of GST, 2016CA K K GUPTA
The document discusses India's proposed Goods and Services Tax (GST) Act and its composition scheme for small businesses. The composition scheme is an optional scheme for registered taxable persons with annual turnover of less than 50 lakhs rupees who are not engaged in inter-state supplies. Under the scheme, tax is paid monthly at a flat rate of 1% of turnover instead of the normal tax. Businesses under the scheme cannot claim input tax credit and can only issue supply invoices, not tax invoices. They are also restricted to only intra-state sales.
Background of Composition Scheme under the GST
Definition under the GST
Eligibility under the GST
Rates of Composition Scheme Dealer
How to Make a Registration and how to file the returns.
Important Definitions
Basic tenets of GST - Dr Sanjiv Agarwal - Article published in Business Advisor, dated May 10, 2016 - http://www.magzter.com/IN/Shrinikethan/Business-Advisor/Business/
Tweeted on www.twitter.com/BusinessAdvDM #BusinessAdvisorArchives
The document discusses Goods and Services Tax (GST) composition scheme in India, which provides a simplified tax structure for small taxpayers. Key points include:
1) The composition scheme is optional for taxpayers with annual turnover up to Rs. 50 lakhs and requires paying a flat rate of tax instead of filing regular returns.
2) Taxpayers in the composition scheme pay taxes quarterly at rates between 1-5% depending on the business and file simplified annual returns.
3) Businesses can exit the composition scheme if their turnover exceeds limits or if they are no longer eligible, and must then start filing regular returns and claiming input tax credits.
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.
Thank You and Happy Reading!!
The document provides an overview of recent changes to tax compliance requirements in India. It discusses updates to income tax laws under the Finance Bill of 2017, including a reduced corporate tax rate for small businesses. It also outlines the key compliance obligations under the upcoming Goods and Services Tax (GST) such as registration requirements, tax return filing, and transitional provisions to carry forward existing tax credits under the new system. Finally, the document presents a chart summarizing the frequency of various compliance filings like TDS returns, VAT returns, and secretarial obligations.
The document discusses the preparedness required by the textile industry for implementing GST by July 1st, 2017. It outlines the indicated GST rates for various textile products and provides 21 steps that the textile industry needs to take immediately, such as taking stock of raw materials and finished goods, finalizing software and invoice/order formats, updating supplier details, and understanding return filing requirements. It also notes that in July 2017, the GST rate on merchant services was sharply cut to 5% from 18% for textile manufacturers.
The document discusses Goods and Service Tax (GST) in India. It introduces GST as an indirect tax implemented on July 1, 2017 that replaced several other taxes including sales tax, central sales tax, service tax, and central excise. GST is made up of four types - IGST, SGST, CGST, and Cess. Goods and services are taxed under GST at rates of 0%, 3%, 5%, 12%, 18%, or 28% and small dealers have the option to use a composition scheme with turnover up to 75 lacs.
This document discusses India's Goods and Services Tax (GST) composition scheme. It provides:
1) An overview of the composition scheme, which allows eligible small businesses to pay tax at 1% of their annual turnover in lieu of regular tax.
2) Eligibility requirements to opt for the composition scheme, including an annual turnover limit of 50 lakhs.
3) Conditions for opting into the scheme, such as restrictions on inter-state supplies and inability to claim input tax credits.
This edition of TransPrice Times provides you with highlights on recently introduced APA roll back rules along with other updates in Transfer Pricing for the first fortnight of March 2015.
The document summarizes the impact of GST on the textile industry in India. Some key points:
- Under GST, taxes like excise duty, VAT, CST etc. will be subsumed and replaced by CGST, SGST and IGST which will remove cascading of taxes and improve input tax credit flow.
- Overall tax incidence on textiles is expected to increase slightly due to higher GST rates compared to previous taxes. This may impact product mix in the industry.
- Compliance burden is also expected to increase initially due to transition challenges but compliance overall will improve in the long run.
- Inter-state trade barriers will be removed, improving competition and organized
The document summarizes key provisions of the composition scheme under the Revised Model GST Law. Taxpayers with an aggregate turnover of less than Rs. 50 lakhs (Rs. 10 lakhs for North Eastern states) can opt for paying GST at a fixed percentage on turnover instead of the regular tax. They will file quarterly returns instead of monthly and are not eligible for input tax credits. The composition scheme is beneficial for small businesses where the input tax rate is low.
Like Central Government, State Governments also make changes in taxes covered in their fold. One major tax collected by States is VAT. Following the footprints of Center, States also make lots of changes under their VAT Act. It is difficult and crucial to get along with the changes proposed in all State VAT Acts. Hence, after hours of research, we have summarised the changes made by States in their VAT Act till date. We have also included reasons contributing to such change at relevant places.
This document provides an introduction and overview of India's GST composition scheme. Key points include:
- The composition scheme is a simple alternative for small taxpayers with turnover less than Rs. 1.5 crore to pay GST at a fixed rate instead of going through regular GST procedures.
- As of 2019, service providers can now opt for the composition scheme if their turnover is below Rs. 50 lakhs.
- To be eligible, total turnover from all businesses with the same PAN must be below Rs. 1.5 crore, and some business types like manufacturers of specific goods are excluded.
- Opting for the composition scheme means no input tax credit can be claimed but
- Value Added Tax (VAT) is calculated as the difference between tax paid on sales and tax paid/payable on purchases within West Bengal during a tax period. It provides a set-off for tax paid on inputs against tax payable on outputs.
- Under VAT, existing dealers and new dealers exceeding certain turnover thresholds must register and pay VAT. All registered dealers are given an 11-digit Taxpayer Identification Number (TIN).
- VAT rates range from 1% to 12.5% for most goods. Exports and sales to special economic zones are zero-rated while some goods are exempted. Dealers have options to pay compounded rates in some cases.
This document provides an overview of the Goods and Service Tax (GST) system that will be implemented in India. It states that GST is a destination-based tax on the consumption of goods and services. It will replace many existing taxes levied by the central and state governments. The document outlines the key features of GST, including what will be taxed, the types of GST (CGST, SGST, IGST), invoice requirements, input tax credit rules, registration requirements, and transitional provisions for existing taxpayers. It concludes by listing several actions businesses need to take to prepare for GST implementation, such as classifying items and updating vendor/customer information.
Composition levy GST ( Composition Scheme GST )CA-Amit
Only taxable persons whose ‘aggregate turnover’ does not exceed Rs. 50 lacs in a financial year will be eligible to opt for payment of tax under the composition scheme.As per Section 16, Goods and/or services on which composition tax has been paid under Section 8 is not eligible for input tax credit.
GST is a comprehensive indirect tax levied on supply of goods and services. India has adopted a dual GST model where both central and state governments can levy GST. Key points include that GST will subsume most indirect taxes, exceptions include alcohol, petroleum and real estate. Registration is required if annual turnover exceeds Rs. 25 lakhs and involves obtaining a 15-digit GST identification number. The document provides details on registration procedures, compounding, exceptions and migration of existing taxpayers to GST.
This document provides an overview of input tax credit (ITC) under the Goods and Services Tax (GST) regime in India. It defines key terms related to ITC such as input, capital goods, input tax, output tax, and reverse charge. It outlines the conditions for claiming ITC and lists items for which ITC is ineligible. It also discusses proportionate credit, adjustments to ITC, transition provisions for claiming ITC on stock, and the process for claiming ITC on inter-state and intra-state supplies.
Ppt on Composition Scheme of GST, 2016CA K K GUPTA
The document discusses India's proposed Goods and Services Tax (GST) Act and its composition scheme for small businesses. The composition scheme is an optional scheme for registered taxable persons with annual turnover of less than 50 lakhs rupees who are not engaged in inter-state supplies. Under the scheme, tax is paid monthly at a flat rate of 1% of turnover instead of the normal tax. Businesses under the scheme cannot claim input tax credit and can only issue supply invoices, not tax invoices. They are also restricted to only intra-state sales.
Background of Composition Scheme under the GST
Definition under the GST
Eligibility under the GST
Rates of Composition Scheme Dealer
How to Make a Registration and how to file the returns.
Important Definitions
The document discusses the benefits of exercise for mental health. Regular physical activity can help reduce anxiety and depression and improve mood and cognitive functioning. Exercise causes chemical changes in the brain that may help protect against developing mental illness and improve symptoms for those who already have a condition.
TransPrice Times 16th March to 3rd April 2015Akshay KENKRE
Dear Readers,
I am pleased to present 'TransPrice Times' for the second fortnight of March 2015. This newsletter provides an insight to significant case laws pronounced and highlights some contentions transfer pricing issues.
Trust you will find it useful.
Happy reading !!!
Please find 'TransPrice Weekly' summarizing a judgement in case of 'Birla Soft P.Ltd' on aggregation of business units.
The judgement highlights the importance of Functional analysis and contractual agreements in resolution of Transfer Pricing dispute.
TransPrice Times 15th to 30th September 2015Akshay KENKRE
Dear Readers,
We are delighted to present second fortnight edition of TransPrice Times for the month of September 2015.
This newsletter gives a snapshot on significant transfer pricing case laws pronounced in relation to issues like marketing intangible, consistency rule and corporate guarantees along with updates on recent happenings in India.
We hope you find it useful and look forward to your feedback.You can write to me at akshaykenkre@transprice.in
Happy reading !!!
TransPrice Times 15th - 31st August 2015Akshay KENKRE
This document summarizes three court cases related to transfer pricing in India:
1) Maruti Suzuki India Ltd - The court agreed with the taxpayer that the TPO incorrectly applied a previous court decision and directed the TPO to follow the manufacturer-specific guidance from another case.
2) Mitsui & Co India Pvt Ltd - The court upheld the taxpayer's view that indenting services and trading are different activities and rejected the TPO's recharacterization of support services as trading.
3) Haier Appliances India Pvt. Ltd - The court ruled in favor of the taxpayer, finding that non-disclosure of a transaction was due to a reasonable belief at the time and no penalty
TransPrice Times 17th - 30th April 2015Akshay KENKRE
Dear Readers,
We present ‘TransPrice Times’ for the second fortnight of April 2015. It provides you with the highlights on range of transfer pricing issues like transactions of intra-group services, selection of comparable and multiple year data which has far-reaching implications in Indian Transfer Pricing landscape.
Trust you will find it useful.
Happy reading !!!
The document discusses the Multilateral Instrument (MLI) Convention, which aims to implement tax treaty related measures to prevent base erosion and profit shifting. The MLI provides solutions to remove loopholes in international tax rules by transposing the results of the OECD/G20 BEPS project into bilateral tax treaties. It will modify covered tax agreements according to participating countries' policy preferences. The MLI establishes minimum standards for tax treaties and allows flexibility for countries in how it affects their treaty networks. India's approval of the MLI will significantly impact its 93 tax treaties. Key effects on India include the principal purpose test and changes to permanent establishment standards.
This document outlines best practices for structuring public-private partnership (PPP) and concession contracts. Key points include:
1. Using output-based contracts focused on performance rather than investment obligations to incentivize efficiency.
2. Requiring adequate insurance, performance bonds, and credit ratings to ensure compliance.
3. Protecting financiers and monitoring concessionaire finances through revenue assignment, financial disclosure, and notification of non-compliance.
4. Establishing clear risk matrices and sharing arrangements based on ability to control risks and potential for externalization.
5. Including provisions for default management, mediation, termination, and credit enhancement of government payments.
The document summarizes three court cases related to transfer pricing in India:
1. In the first case, the court ruled in favor of Thomas Cook (India) Limited and held that AMP expenditures could not be considered an international transaction without direct evidence of benefit to an associated enterprise.
2. In the second case, the court ruled against ZTE Corporation and considered the economic life of the permanent establishment in determining profit attribution. It also ruled more profits could be attributed if functions, assets and risks were not properly analyzed.
3. In the third case, the court ruled against Aptara Technologies and directed it to use single year data for transfer pricing analysis unless multiple-year data could be proven more functionally
Dear Readers,
We are pleased to present TransPrice Times for the first fortnight of June 2016.
In this bulletin, OECD continues to propose key inputs and seeks to incorporate major issues and amendments relating to Action 8-10 (Transfer Pricing), Action 13 (CbC reporting) and Action 15 (Multilateral Instruments) of the BEPS Project.
Further, some key issues in the Indian litigation revolving around use of multiple year data, attribution of profits and marketing intangibles are addressed.
We hope you find this newsletter both timely and useful, and we look forward to your feedback and suggestions to improve it further. You can write to us at akshaykenkre@transprice.in
Happy Reading!!!
Presentation on public procurement and competition concern11Dhruv Bhatia
Public procurement involves government agencies obtaining goods, services, and technologies using public funds. It contributes 15-20% of GDP in India and is governed by rules like the General Financial Rules. Major areas of public procurement include defense, railways, health, and telecom which together account for around 50% of public procurement. The primary objective is to achieve value for money by procuring best goods and services at lowest cost. Common procurement mechanisms involve a tendering process with separate evaluation of technical and financial bids. Some examples of bid rigging in public procurement cases in India include companies submitting identical bids or dividing markets. Factors that can indicate bid rigging include identical pricing, last minute adjustments to bids, and suppliers meeting privately before submitting
This document discusses the Multilateral Instrument (MLI) Convention, which aims to implement tax treaty related measures from the OECD/G20 BEPS Project to prevent base erosion and profit shifting. The MLI will modify over 3000 bilateral tax treaties. Key features of the MLI include introducing principal purpose tests to prevent tax avoidance, adopting simplified limitation of benefit clauses, expanding definitions of permanent establishment, and improving dispute resolution mechanisms. India has signed the MLI and it will modify India's 93 tax treaties, though the effects on some treaties are unclear as not all countries participated. The MLI provides flexibility for each country to choose which provisions to adopt and will help address treaty shopping and other BEPS issues.
The ITAT Hyderabad case involved a taxpayer that provided corporate guarantees to its overseas subsidiary without receiving any remuneration. The tax officer determined this constituted an international transaction requiring arm's length pricing and imposed a transfer pricing adjustment, treating the bank commission rate as the appropriate guarantee fee. The taxpayer argued guarantees do not involve costs or risk. The court held corporate guarantees are international transactions that require remuneration and benchmarking, and cannot be equated to bank guarantees. The case was remanded to determine an appropriate guarantee fee rate.
Dear Readers,
We are pleased to present ‘TransPrice Times’ for the first fortnight of May 2015, providing highlights on transfer pricing developments.
We aim to provide an insight into some contentious transfer pricing issues and also equip you with the information on latest happenings in India.
Trust you will find it useful.
Happy reading !!!
Please give your feedback on following link: info@transprice.in
TransPrice presents to you TransPrice Times for January 2015. It equips the reader with recent developments along with detailed discussion on the latest case laws.
Trust you will find it useful.
Happy reading !!!
The governments of India and Mauritius signed a protocol in May 2016 to amend their existing double taxation treaty. Key amendments include source-based taxation of capital gains on shares acquired on or after April 1, 2017. A limitation of benefits article introduces tests regarding motive, activity, and expenditures to qualify for a reduced 50% tax rate on capital gains during a two-year transition period. Interest paid to Mauritian banks will now be taxed in India at 7.5% for debt post March 31, 2017. The protocol also provides for improved exchange of information and introduces concepts like taxation of fees for technical services and permanent establishments.
Baker Tilly Presents: New to Cost Reimbursement Contracts? Meet Your New Frie...BakerTillyConsulting
Presented at NCMA's World Congress 2016
Presenters: Baker Tilly's Brent Calhoon, CPA, Partner and Jennifer Flickinger, Partner
The world of cost reimbursement contracts has many exciting twists and turns. Contractors have to be ready to tackle the roller-coaster ride that comes with these complex contracts. This session provides an overview of some of the strict regulatory requirements that come into play as contract value and risk increase. The presenters will touch on the business system criteria, annual cost reporting requirements, the Cost Accounting Standards, and more. www.bakertilly.com/governmentcontractors
India Inc. endorses Government’s Speed of Decision making and Implementation Agenda. Sumit Mazumder, President, CII, addressed CII's first Press Conference on its National Agenda 2015-16. Since coming to power in May 2014, the new government has adopted several measures to generate positive sentiment about the Indian economy. CII’s theme for the year is to Build India: Invest in Development. This would involve CII’s engagement in four broad areas: promoting growth and competitiveness, developing human capital, promoting infrastructure investments encouraging social development. CII is involved in three national missions – on smart cities, on digital India and on Sanitation in schools. CII is working with central, state and local governments for the successful implementation of these missions.
TransPrice Times 1st - 15th August 2015Akshay KENKRE
Dear Readers,
We are pleased to present the first fortnight edition of TransPrice Times for August 2015.
The newsletter highlights important transfer pricing judgement that provides guidance on computation of capacity utilization adjustment and alerts including APA rollback scheme and MAP proceedings between India and US.
Trust you will find it useful.
Happy reading !!!
TransPrice Times - 16th - 28th February 2018Akshay KENKRE
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!!
Similar to TransPrice Weekly March Week 4_2014 (20)
As a foreign company doing business with Indian consumers, you might want to evaluate the impact of the Equalisation levy on your supply chain. It is a 2% levy that you may like to factor in your global taxes or get it structured it right.
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.
We trust you will find this update useful and informative.
We would be happy to know your suggestions. You can write to us at akshaykenkre@transprice.in
Thank You and Happy Reading!!
This document summarizes several transfer pricing cases from the TransPrice Times publication.
The first case discusses Vodafone Essar Digilink Ltd. where the ITAT rejected the use of a foreign comparable transaction to benchmark royalty payments. However, it also rejected the tax officer's argument of nil royalty.
The second case discusses Blue Scope Steel India Private Limited, where the ITAT accepted the taxpayer's argument that seconded employees were on its payroll, so salary reimbursements should be allowed.
The third case discusses Amphenol Interconnect India Private Ltd. where the High Court upheld the Tax Court's use of TNMM over CUP and rejected differences in sales commissions.
The last case
TransPrice Times - 16th January 2018 - 15th February 2018Akshay KENKRE
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
Thank You and Happy Reading!!
Apart from this, recent news on implementation of BEPS measures in the India-China tax treaty has been highlighted in the periodical.
It gives me a pleasure to present the summary and analysis of Union Budget 2018.
Union Budget 2018 proves a stepping stone towards rising governance and analyzing direct tax proposals that will help India maintain its stand as the fastest growing economy in the world.
With the aim to provide you an economic overview and direct tax proposals, this snapshot also decodes the impact of each and every provision on you and your company.
Hope you find this analysis useful in taking business decisions and align your company's strategy with overall economic climate for the upcoming financial year.
Would love to hear your feedback on the usefulness of the same.
Thanks a lot.
TransPrice Times - 16th December 2017 - 15th January 2018Akshay KENKRE
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.
Apart from this, recent news relating to India’s activation of bilateral exchange relationships for CbC & CRS MCAA has been discussed in the periodical.
TransPrice Times - 1st - 15th December 2017Akshay KENKRE
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.
Thank You and Happy Reading!!
TransPrice Times - October & November 2017Akshay KENKRE
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.
Thank You and Happy Reading!!
TransPrice Times 16th - 31st August 2017Akshay KENKRE
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
Thank You and Happy Reading!!
TransPrice Times - 1st - 15th August 2017Akshay KENKRE
Dear Members,
We are pleased to present TransPrice Times for first fortnight of the month of August 2017.
This periodical broadly covers important rulings, addressing different key issues pertaining to associated enterprises, allocation of unallocable costs among business segments, and determination of most appropriate methods in transfer pricing.
Thank You and Happy Reading!!
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 InstrumentsAkshay KENKRE
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.
The MLI Special Edition urges our members to traverse the multilateral wave, and understand the implications of MLI on the tax front. This edition covers a simplified analysis of India's position on MLI, FAQs & tool-kits released by OECD.
We would be happy to know your suggestions. You can write to us at akshaykenkre@transprice.in
Thank You and Happy Reading!!
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
Thank you and Happy Reading !!
TransPrice Times - 16th - 31st May 2017Akshay KENKRE
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 2017Akshay KENKRE
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.
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
Thank You and Happy Reading!!
TransPrice Times 16th - 31st March 2017Akshay KENKRE
Dear Members,
We are pleased to present TransPrice Times for the second fortnight of March 2017.
This periodical covers the important amendments made to Finance Bill 2017, which has now received the Presidential assent. In other recent updates, this issue covers the circular on Income Computation and Disclosure Standards (ICDS) released by CBDT, while the Tax Courts have delivered important rulings addressing key transfer pricing issues related to recharacterization of share application, depreciation adjustment.
We would be happy to know your suggestions. You can write to us at akshaykenkre@transprice.in
Thank You and Happy Reading!!
Dear Members,
We are pleased to present TransPrice Times for the first fortnight of March 2017.
This periodical covers important rulings addressing key transfer pricing issues related to profit level indicators, basket approach for benchmarking practices, foreign exchange gains, etc. Further, a detailed analysis of the recently notified norms by RBI, for FDI in Limited Liability Partnerships has been provided.
We would be happy to know your suggestions. You can write to us at akshaykenkre@transprice.in or at https://www.transprice.in/ask-query.html
Thank You and Happy Reading!!
how to sell pi coins effectively (from 50 - 100k pi)DOT TECH
Anywhere in the world, including Africa, America, and Europe, you can sell Pi Network Coins online and receive cash through online payment options.
Pi has not yet been launched on any exchange because we are currently using the confined Mainnet. The planned launch date for Pi is June 28, 2026.
Reselling to investors who want to hold until the mainnet launch in 2026 is currently the sole way to sell.
Consequently, right now. All you need to do is select the right pi network provider.
Who is a pi merchant?
An individual who buys coins from miners on the pi network and resells them to investors hoping to hang onto them until the mainnet is launched is known as a pi merchant.
debuts.
I'll provide you the what'sapp number.
+12349014282
Abhay Bhutada Leads Poonawalla Fincorp To Record Low NPA And Unprecedented Gr...Vighnesh Shashtri
Under the leadership of Abhay Bhutada, Poonawalla Fincorp has achieved record-low Non-Performing Assets (NPA) and witnessed unprecedented growth. Bhutada's strategic vision and effective management have significantly enhanced the company's financial health, showcasing a robust performance in the financial sector. This achievement underscores the company's resilience and ability to thrive in a competitive market, setting a new benchmark for operational excellence in the industry.
Yes of course, you can easily start mining pi network coin today and sell to legit pi vendors in the United States.
Here the what'sapp contact of my personal vendor.
+12349014282
#pi network #pi coins #legit #passive income
#US
1. Elemental Economics - Introduction to mining.pdfNeal Brewster
After this first you should: Understand the nature of mining; have an awareness of the industry’s boundaries, corporate structure and size; appreciation the complex motivations and objectives of the industries’ various participants; know how mineral reserves are defined and estimated, and how they evolve over time.
Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
Una ricerca de il Club degli Investitori, in collaborazione con ToTeM Torino Tech Map e con il supporto della ESCP Business School e di Growth Capital
Lecture slide titled Fraud Risk Mitigation, Webinar Lecture Delivered at the Society for West African Internal Audit Practitioners (SWAIAP) on Wednesday, November 8, 2023.
BONKMILLON Unleashes Its Bonkers Potential on Solana.pdfcoingabbar
Introducing BONKMILLON - The Most Bonkers Meme Coin Yet
Let's be real for a second – the world of meme coins can feel like a bit of a circus at times. Every other day, there's a new token promising to take you "to the moon" or offering some groundbreaking utility that'll change the game forever. But how many of them actually deliver on that hype?
STREETONOMICS: Exploring the Uncharted Territories of Informal Markets throug...sameer shah
Delve into the world of STREETONOMICS, where a team of 7 enthusiasts embarks on a journey to understand unorganized markets. By engaging with a coffee street vendor and crafting questionnaires, this project uncovers valuable insights into consumer behavior and market dynamics in informal settings."
What price will pi network be listed on exchangesDOT TECH
The rate at which pi will be listed is practically unknown. But due to speculations surrounding it the predicted rate is tends to be from 30$ — 50$.
So if you are interested in selling your pi network coins at a high rate tho. Or you can't wait till the mainnet launch in 2026. You can easily trade your pi coins with a merchant.
A merchant is someone who buys pi coins from miners and resell them to Investors looking forward to hold massive quantities till mainnet launch.
I will leave the what's app number of my personal pi vendor to trade with.
+12349014282
when will pi network coin be available on crypto exchange.DOT TECH
There is no set date for when Pi coins will enter the market.
However, the developers are working hard to get them released as soon as possible.
Once they are available, users will be able to exchange other cryptocurrencies for Pi coins on designated exchanges.
But for now the only way to sell your pi coins is through verified pi vendor.
Here is the what'sapp contact of my personal pi vendor
+12349014282
1. Weekly
24th
-31st
March 2014
Contact us: Gita Building, 2nd
Floor, Plot No. 92, Next to HP Petrol Pump, Sion East, Mumbai – 400022
Tel: 022-24097171; Mobile: +91 9819245424; email: akshaykenkre@transprice.in
CBDT Signs 5 APAs
Category: News
As a step to restore certainty in the tax regime in India, the Indian Government has signed 5
Advance Pricing Agreements (APAs) with MNCs operating in different industry sectors
Signing the agreements on the last day of the financial year, CBDT has kept its word by executing
the agreements in Financial Year 2013-14
The agreements cover a period of 5 years and specifies Arm’s Length Price for the international
transactions entered in to by 5 tax payers
The transactions include interest payments, corporate guarantee, investments advisory services
and contract manufacturing in different industry sectors like Pharmaceuticals, Telecom and
Financial Services
The first set of agreements are concluded in about a year which is a proactive sign of Government’s
conscious policy of non –adversarial tax regime
I-Flex Solutions Limited: Bombay High Court
Decision Outcome: In favour of the Taxpayer
Category: Payment of commission
High Court (HC) upheld Tribunal’s order on payment of higher commission to the subsidiaries /
Associated Enterprises
HC observed that the subsidiaries performed additional activities relating to customization and
hence, such an additional payment is justified
One can conclude, that it is important to document and differentiate the activities undertaken by
the taxpayer vis-à-vis the comparable companies. If a higher pay out needs to be made in relation
to the function undertaken, the same needs to be justified with requisite documentation