Sunday , July 13, 2025 |   16:16:01 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
TP - While principle of res judicata does not apply to tax proceedings, the principle of consistency must be observed, especially where there is no change in facts or legal position: ITAT (See Breaking News) TP - Provision for bad & doubtful debts is only accounting treatment and have no direct nexus to operating income: ITAT (See Breaking News) TP - Working capital adjustment can't be denied merely due to absence of detailed working capital cycle data and adjustment should be granted based on average of opening & closing balances: ITAT (See Breaking News) DTAA - Prior taxability of similar income in earlier years does not bar assessee's lawful claim for relief in current year, more so when there is no change in facts: ITAT (See Breaking News) Netherlands to grow at 1.3% rate in 2025: OECD (See Brief) TP - Corporate guarantee given by assessee on behalf of AE in absence of any expenditure being incurred by assessee, would not constitute international transaction within meaning of Sec 92B: ITAT (See Breaking News) TP - Gross profitability margin may vary significantly over time, and hence, reliance on data of earlier years would not constitute reliable benchmark: ITAT (See Breaking News) DTAA - Management support services do not make available any technical knowledge or skill to recipient; ergo, consideration therefor is not taxable as FTS under India-Singapore DTAA: ITAT (See Breaking News) I-T - Amortization of capital subsidy in itself is not allowable as direct deduction u/s 80-IC, rather impact of capital subsidy is reflected in reduced "actual cost" of asset, leading to claim of lower depreciation: ITAT (See Breaking News) I-T - If repair & maintenance of aircraft equipment provided by foreign assessee to Indian airline operators, did not involve transfer of technology, then receipts from said services are not taxable as FIS: HC (See Breaking News) TP - If number of transactions are closely linked, then same should be treated as composite transaction and can be aggregated and construed as single transaction for purpose of determining ALP: ITAT (See Breaking News)
 
TII SEARCH
 
 
   
Home >> News Brief
 

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.

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.