India - International Tax Review
WEBSep 4, 2024 · Budget 2024: A bold agenda to simplify India’s tax framework. The policies unveiled in India’s recent budget announcement should stimulate both domestic growth and foreign investment, write Ritu Shaktawat and Viraj Doshi of Khaitan & Co. Ritu Shaktawat, August 06, 2024. Sponsored.
EY Asia-Pacific Guide | International Tax Review - ITR
WEBDec 14, 2023 · EY’s Asia-Pacific Guide 2023: Transformational tax trends. ITR has collaborated with EY to provide insights into the most pressing tax issues in the Asia-Pacific region as the pace of change shows no sign of abating. Sponsored by. BEPS 2.0: the implementation of pillar two in Asia-Pacific. Senior EY …
MLI: Testing the ‘principal purpose’ | International Tax Review
WEBDec 12, 2018 · The MLI essentially allows the tax treaty-related measures of the OECD/G20 BEPS project to be introduced into the existing tax treaties of the signatories to the convention in a consistent and efficient manner, eliminating the need to renegotiate every bilateral tax agreement separately. The MLI positions adopted by each participating ...
IP transfers: Tax and accounting considerations
WEBDec 17, 2012 · Royalties paid in exchange for the right to use or exploit IP outside of the US are typically foreign-source income – IRC §862(a)(4). In contrast, the gain from the sale of IP – patents, copyrights, secret processes or formulas, goodwill, trademark, trade brand, franchise, or other like property – is generally sourced under IRC §865 according to the residence of the seller.
Understanding the beneficial ownership v. beneficial holding …
WEBSep 14, 2021 · The concept of ‘beneficial ownership’ is found under the international tax treaties. The tax treaties are negotiated based on the model tax conventions and these conventions inter alia provide explanations as to the intent and purpose behind terms appearing therein. The phrase ‘beneficial owner’ appears in both the OECD Model Tax Convention and the UN Model Tax Convention in the ...
India: Analysing foreign portfolio investor taxation in India - ITR
WEBOct 15, 2019 · Foreign institutional investors (FII) have enjoyed a beneficial tax regime in India since the introduction of section 115AD of the Income-tax Act 1961 (Act), via the Finance Act 1993. The beneficial regime was introduced following a policy decision that was taken by the government with a view to attracting foreign investment to India.
Treatment of forex gains and losses in transfer pricing
WEBAug 22, 2012 · Any unheralded deviation from the projected rate could result in a loss or gain situation. An enterprise has little or no control on this loss or gain; therefore it may be termed as an unplanned result if Forex risks are not fully hedged. In transfer pricing, whether forex gain or loss is to be treated as an operating income or loss is an issue.
Deferred taxes – the initial recognition exception (IRE) related to ...
WEBDec 2, 2014 · Book value. Gross up factor. 1 -30% . Gross up amount of the asset with the related deferred income tax. $1,000/70% Notes. $1,000. 70%. $1,428. Recognise a deferred tax expense of $428 by adjusting the carrying value of the book value of the asset.
How to minimize the global PE risk | International Tax Review - ITR
WEBMay 31, 2002 · The issue of taxable presence and permanent establishment (PE) is among the foundation stones of international taxation. Understanding the circumstances in which a multinational corporation's (MNC) actual or deemed activities in any given foreign country will be considered sufficient to subject the company to net income taxation in that jurisdiction is a true global issue.
US tax reforms impact on cross-border M&A | International Tax …
WEBMay 31, 2019. While US tax reform may not have affected merger and acquisition (M&A) activity explicitly, a change in laws surrounding controlled foreign corporations (CFCs) will see a number of new tax considerations emerge for US buyers and sellers. Fenwick & West’s Adam Halpern and William Skinner discuss how these changes might influence ...
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