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TP - Company engaged into diversified activities being a big brand, cannot be compared to a routine captive service provider, that too in absence of segmental reporting: ITAT(See 'Breaking News') TP - AMP expenses incurred by Indian entity for promotion of its business cannot be termed as 'international transaction', in absence of any of its arrangement with overseas AEs: ITAT (See 'Breaking News') TP - Extra ordinary events witnessed by a company during particular year, does not calls for its exclusion for comparable analysis, without probing its impact of profitability: ITAT(See 'Breaking News') TP - Company having fluctuating operating margin, are no good comparable for purposes of benchmarking: ITAT(See 'Breaking News') I-T - Interest paid on ECBs lend by foreign branch of resident banking company, attracts no TDS liability u/s 195: ITAT (See 'Breaking News') I-T - Freight charges for import made from AEs attracts no withholding tax liability u/s 195, merely because telegraphic transfer of remittances towards AEs were made from bank in India: ITAT (See 'Breaking News') TP - Writ Court should not entertain an issue framed before it, when such an issue is beyond the one as raised before the Tribunal: HC (See 'Breaking News') TP - Rendering of common ITES services will not make two enties comparable to each other, unless their business model are similar: HC (See 'Breaking News') TP - No ALP adjustment is warranted on model fees & royalty, if no products are sold to AEs on which royalty is payable and entire amount of royalty was paid on sales made to independent enterprises: ITAT (See 'Breaking News') TP - Company engaged in multifarious activities besides tour operation and having its own brand value, cannot be considered as good comparable to a tourism company: ITAT (See 'Breaking News') I-T - Taxpayer cannot be held responsible for witholding taxes on source u/s 195 anticipating a restrospective amendment in the future: ITAT (See 'Breaking News') Investment by Foreign Portfolio Investors (FPI) in Debt - Review (See 'RBI Circular' in FDI) I-T - No NRI is permitted to open foreign bank account by using proof of identity as mentioned in Indian passport, once he has accepted foreign nationality and surrendered Indian citizenship: ITAT (See 'Breaking News') I-T - Furnishing of evidences of TDS deduction u/s 195 along with Form 15CB, is no pre-requisite for preferring appeals u/s 246, when matter relates to foreign remittances for services rendered abroad: ITAT (See 'Breaking News') TP - Written down value of cranes in books of overseas AEs, cannot be considered as ALP in an international transaction of import of cranes from those AEs: ITAT (See 'Breaking News')
 
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Action 5 - Report on 44 tax jurisdictions released
By TII News Service
Dec 07, 2017 , New Delhi

    

AS part of continuing efforts to improve tax transparency and the international tax framework, the OECD has released the first analysis of individual countries' progress in spontaneously exchanging information on tax rulings in accordance with Action 5 of the BEPS package of measures released in October 2015.

The first annual report on the exchange of information on rulings evaluates how 44 countries, including all OECD members and all G20 countries, are implementing one of the four new minimum standards agreed in the OECD/G20 BEPS Project.

A key aim of the project was to increase transparency, which resulted in a new minimum standard to ensure that information on certain tax rulings is exchanged between relevant tax administrations in a timely manner (Action 5). This minimum standard requires tax administrations to spontaneously exchange information on rulings that have been granted to a foreign related party of their resident taxpayer or a permanent establishment which, in the absence of exchange, could give rise to BEPS concerns. As a minimum standard, all members of the Inclusive Framework on BEPS have committed to implement this standard, and to have their compliance with the standard reviewed and monitored by their peers.

The standard covers rulings such as advance pricing agreements (APAs), permanent establishment rulings, related party conduit rulings, and rulings on preferential regimes. More than 10000 relevant rulings were identified up to the end of 2016.

The annual report includes almost 50 country-specific recommendations on issues such as improving the timeliness of the exchange of information, ensuring that all relevant information on the taxpayer’s related parties is captured for exchange purposes, and ensuring that exchanges of information are made with respect to preferential tax regimes that apply to income from intellectual property.

The next annual peer review will cover all members of the Inclusive Framework, except for the developing countries that requested a deferral of their review to 2019.

 
 
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