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    Monday , September 1, 2014 |   04:52:42 IST
     
    INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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    NEWS FLASH
     
    I-T - Whether word "charter" completely eludes concept of ownership - Whether a charterer of a ship can be owner of a ship- Whether meaning of word "charterer" can be imported from or to be understood from meaning of word "owner" or "lessee" as used in Article 8 of India-Malaysia DTAA (See 'TII Breaking News') I-T - Whether question of treating person responsible for paying income to non-resident as assessee in default by way of passing order u/s 201(1) is tied with tax liability of payee on such sum (See 'TII Breaking News') Agreement of Social Security with Czech Republic with effect from 1st September, 2014 (See 'SSAs' in Visa) I-T - Whether when it is only publication of a notice u/s 560(3) of Companies Act in official Gazette that a company stands dissolved, and rights of assessee holding shares of said company get extinguished but prior to that point of time, it cannot be said that there was any transfer to invoke provisions of section 45 of I.T. Act - Whether when there is no receipt of money or other assets on liquidation (See 'TII Breaking News') TP - Whether when a loan is given to a subsidiary, it carries a lower risk since assessee has indirect control over it - Whether assessee not having charged any interest, Libor + a nominal interest should represent appropriate TP adjustment (See 'Breaking News') TP - Whether without rejecting merits of filters adopted by assessee, TPO can, on a selective basis ignore such filter - Whether even if a (See 'Breaking News') Order under section 119 of the Income-tax Act (See 'Administrative Orders' in Intl Taxation) TP - Whether Act and Rules contemplate determining ALP by aggregating international transactions which are multiple, interlinked or inter-related to each other and cannot be (See 'Breaking News') I-T - Whether when in case of a CRS company, in assessment order Assessing Officer has mentioned that facts and circumstances of case remain same as in earlier years wherein Tribunal had found on a FAR analysis that Indian PE performed limited functions for which only 15% of revenue could be attributed and such attribution of Tribunal has been upheld by High Court in different cases (See 'TII Breaking News') P S Sivasankaran goes to OECD's Global Forum on Transparency & Exchange of Information for Tax Purposes (See 'Administrative Orders' in Intl Taxation) Policy for Private Investment in Rail Infrastructure through Domestic and FDI (See 'Press Notes' in Fdi) I-T - Whether without examining as to what technicality was involved in providing service by a non-resident - Whether a person can not learn those technical aspects in a 10 years time (See 'TII Breaking News') Review of FDI for Defence sector (See 'Press Notes' in Fdi) TP - Whether even though profits of Infosys BPO is reasonable and no super profits are earned, because of its big brand value, it has to be excluded on grounds of functional dissimilarity on FAR Analysis- Whether mere fact that two services are placed in CBDT circular under ITES category, makes them automatically comparable (See 'Breaking News') TP - Whether a company with a turnover of around Rs 47 crore, would fall within category of companies in range of turnover between 1 crore and 200 crores- Whether in such a case, companies having turnover of more than 200 crores have to be eliminated from list of comparables (See 'Breaking News') I-T - Whether a decision of High Court can be a good ground to reopen assessment - Whether revenue from services which are technical in nature in a business to which section 44BB applies, does not fall within ambit of section 44BB(1), but is taxable under provisions of either section 44D or section 115A (See 'TII Breaking News') TP - Whether even though profit of Infosys BPO Ltd. is reasonable and no super profits are earned, it can be used as a comparable for an ITES company considering its big brand value and huge export turnover (See 'TII Breaking News')
     
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    TII BREAKING NEWS
     
    I-T - Whether question of treating person responsible for paying income to non-resident as assessee in default by way of passing ....
    I-T - Whether word "charter" completely eludes concept of ownership - Whether a charterer of a ship can be owner of a ....
    I-T - Whether when it is only publication of a notice u/s 560(3) of Companies Act in official Gazette that a company stands dissolved, and ....
    TP - Whether when a loan is given to a subsidiary, it carries a lower risk since assessee has indirect control over it - Whether ....
    < More News >
     
    TII EXCLUSIVE Aug 04, 2014
     
    No, not Letters 3!
    By Laurence E Lipsher

    No, no, no - I am not devoting this essay to letters! I've done that the past two articles published in this exact same place - I'm not saying that there will not be a Letters 3....but not this time. True, I will mention some letters at the start of my ....

     
    TII EDIT Aug 19, 2014
     
    Our REITs, their REITs
    By D P Sengupta

    REAL Estate Investment Trust [REIT] is an American invention and has more than 50 years of history. Dwight D Eisenhower introduced REIT as part of Cigar Excise Tax Extension of 1960. According to reit.com, 50th anniversary of US Reit industry was celebrated on September 14, 2010.

    The basic idea behind the creation of REIT ....

     
    TII SPECIAL Aug 08, 2014
     
    Interpretation issues relating to 'other income'
    By A J Majumdar

    A comprehensive agreement for avoidance of double taxation and prevention of fiscal evasion on the lines of OECD or UN Model Conventions, in principle, is presumed to include in its scope all kinds of incomes which are subjected to income-tax by the contracting sovereign States under their domestic tax laws, ....

     
    TII BRIEF
     
    Washington, Aug 21, 2014
    IMF to release new Fiscal Transparency Manual for member countries...
    Washington, Aug 20, 2014
    IFC unveils tax reforms project for Caribbean States ...
    Washington , Aug 13, 2014
    IMF paper focuses on challenges in Japan's corporate income tax reforms...
    Manila, Aug 12, 2014
    ADB's ICT toolkit highlights innovations in tax systems...
    Paris, Aug 05, 2014
    Global Forum releases new compliance ratings on tax transparency - Barbuda, Indonesia rate...
     
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