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TP - Incurring of losses at entity level or accrual of less economic benefit, is no criteria to determine ALP of royalty payment to AEs in respect of technical know how, at NIL: ITAT (See 'Breaking News') TP - Revised grounds filed by assessee against TP adjustment towards services related to AEs, merits no adjudication, if it is already settled as per MAP Procedure: ITAT (See 'Breaking News') TP - Accrual of tangible economic benefit to Indian entity on account of technology received from overseas AE, is no prerogative for making ALP adjustment in case of royalty paid to AEs: ITAT (See 'Breaking News') TP - No Company can be excluded from set of final comparable merely because it is making loss at operating profit level: ITAT (See 'Breaking News') I-T - Belated claim for seeking refund of excess TDS deducted mistakenly, while making payment of royalty to overseas AE, is no ground to deny such refund: HC (See 'Breaking News') TP - Assessment framed against non-existing entity is a not a procedural irregularity, which can be cured by invoking provisions of section 292B: ITAT (See 'Breaking News') TP - Failure of AO to ascertain most appropriate method for determination of ALP in relation to its international transaction with AEs, paves way for revisional jurisdiction: ITAT (See 'Breaking News') TP - When impact of receivables have been factored in working capital adjustment and thereby on its pricing/profitability vis--vis comparables, then no further adjustment is called for: ITAT (See 'Breaking News') I-T - TDS reconcilliation statement cannot be relied solely, for exercising revisional jurisdiction, without recording any impact on income by reason of international transaction in terms of Sec 92: ITAT (See 'Breaking News') Global bodies call for mobilising domestic taxes to meet SDGs (See 'TII 'Brief') TP - Reference made to TPO for computation of ALP of international transaction, in absence of approval from appropriate authority u/s 92CA, is jurisdictional defect: ITAT (See 'Breaking News') TP - ALP adjustment made in name of a non existing entity, which had been previously amalgamated by order of Writ Court, should not be sustained: ITAT (See 'Breaking News') TP - Internal CUP method benchmarked by assessee as MAM while computing ALP, cannot be disregarded, merely because of different pricing mechanism in case of AE and non-AEs: ITAT (See 'Breaking News') India, Iran sign Protocol to amend DTAA (See 'TII Brief') TP - Rate of Royalty approved by SIA / RBI will constitute CUP data, and hence international transaction comprising such royalty payment, is to be treated at ALP: ITAT(See 'Breaking News') I-T - Withholding tax liability on transponder rent & downlinking charges paid to overseas AE, cannot be determined without verifying that recipient AE had incorporated such payments its income: ITAT (See 'Breaking News')
 
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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".

 
 
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