Tuesday , May 22, 2018 |   23:14:03 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Instant Updates Newsletters
 
NEWS FLASH
 
I-T - Major relief for Shah Rukh Khan; Levy of penalty came to be relaxed as income from house property held by him in Dubai was held being not notionally taxable in India: ITAT (See 'Breaking News') BEPS Action 5 - Review - Four regimes asked to remove harmful tax practices (See ‘Brief’) TP - Safe Harbour Rules merits consideration, for purposes of computation of operating margin: ITAT (See 'Breaking News') DTAA - Mere charging of royalty from Indian franchise outlets for purpose of safeguarding the brand value, will not render Indian outlet as PE of the foreign principal company: ITAT (See 'Breaking News') TP - Non comparability of products manufactured by two companies even at a broad level, renders them unfit for comparison for purposes of benchmarking: ITAT (See 'Breaking News') I-T - Withholding tax liability can be attached to the payer while making payments to non-residents, only if such payments are chargeable to tax in India: ITAT (See 'Breaking News') TP - Departmental Representative cannot question selection of comparables made by TPO: ITAT (See 'Breaking News') TP - Mistake crept in order which is apparent on record, merits rectification by appropriate authority/forum upon being noticed: ITAT (See 'Breaking News') I-T - Corporate guarentee extended by Indian entity to its overseas AEs without charging any fees, are outside the ambit of international transaction: ITAT (See 'Breaking News') TP - Balance of convenience and relative hardship in favour of assessee, also merits interim stay in his favour: ITAT (See 'Breaking News') I-T - Mistaken name of authority in an order, merits rectification by replacement of correct name: ITAT (See 'Breaking News') DTAA - Consideration received by UK entity from customers in India towards offshore supply of software, cannot be charged to tax in India under I-T Act r/w India UK DTAA: ITAT (See 'Breaking News') I-T - Receipts in relation to prospecting or extraction of mineral oil, are liable for presumptive taxation u/s 44BB: ITAT (See 'Breaking News') TP - When draft assessment order passed by AO stood withdrawn upon objections raised before DRP u/s 144C, then appeal preferred against such order becomes infructuous: ITAT (See 'Breaking News') TP - ALP adjustment becomes indispensible on account of capacity utilization, where depreciation and idle capacity was affecting margins of assessee more than the comparables: ITAT (See 'Breaking News') I-T - Department should not levy unusual interest on assessee u/s 201(1A) for default in TDS obligation on foreign payments, without directing explanation from assessee: HC (See 'Breaking News') TP - Transfer pricing adjustment on account of unutillized capacity, merits consideration before proceeding to determine ALP in international transaction comprising of lease rent: ITAT (See 'Breaking )
 
TII SEARCH
 
 
   
Home >> News Brief
 

BEPS - OECD releases addl guidance on Action 13
By TII News Service
Feb 09, 2018 , NEW DELHI

    

THE Inclusive Framework on BEPS has released additional guidance to give certainty to tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) reporting (BEPS Action 13). The Inclusive Framework also approved updates to the results for preferential regime reviews conducted by the Forum on Harmful Tax Practices (FHTP) in connection with BEPS Action 5.

The additional guidance addresses two specific issues: the definition of total consolidated group revenue and whether non-compliance with the confidentiality, appropriate use and consistency conditions constitutes systemic failure. The complete set of guidance related to CbC reporting issued so far is presented in the document released today. Also released today is a compilation of the approaches adopted by member jurisdictions of the Inclusive Framework with respect to issues where the guidance allows for alternative approaches. These documents will continue to be updated with any further guidance that may be agreed.

Members of the Inclusive Framework are continuing to make progress in delivering the international standard on BEPS Action 5. Two Barbados' regimes, the International financial services and the Credit for foreign currency earnings/Credit for overseas projects or services, were concluded as "potentially harmful" by the Inclusive Framework in the 2017 Progress Report on Preferential Regimes. In a ministerial letter Barbados committed to amend these regimes within the FHTP's agreed timelines and in accordance with the criteria of the FHTP. The Inclusive Framework therefore agreed to update the conclusions for these two regimes to "in the process of being amended".

Canada's regime for international banking centres (IBCs) was determined to be "potentially but not actually harmful" by the FHTP in the 2004 Progress Report. Canada has abolished the IBC regime, with limited grandfathering which is consistent with the FHTP guidance and therefore the conclusion for this regime is updated to "abolished".

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAAs
  • TIEAs
  • Circulars (I-T Act, 1922)
  • Circulars
  • Instructions
  • DRP Panel
  • Administrative Orders
  • Notifications
  • I-T Act, 1961
  • Relevant Portion of I-T Rules,1962
  • Relevant Portion of I-T Act,1922
  • GAAR
  • Equalisation Levy
  • Draft Guidelines
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • DTC Bill
  • UN Model
  • Miscellaneous
  • Guidance Notes - AEOI
  • OECD Conventions
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • Circulars
  • Instructions
  • Notifications
  • Relevant Sections of Act
  • TP Rules
  • Forms
  • Miscellaneous
  • APA Annual Report
  • APA Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • RBI Circulars
  • FDI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • Black Money Act
  • PMLA Notification
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • SEBI
  • Multimodal Transportation
  • Vienna Convention
  • NBFC Reports
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • Intellectual Property
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • CBR Act, 1963
  • MCA Circular
  • Book Review
  • Limitation Act
  • SSAs
  • EPFO
  • FAQs
  • Acts
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifcations
  • Types of Visa
  • Agreements
  • Arbitration
  • Model Text
  • Relevant Portion of I-T Act
  • Circulars
  • I-T Rules, 1962
  • MISC
  • Notification
  • Subscribe
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2018 Taxindiainternational.com Pvt.Ltd. All rights reserved.