Download or read book Taxmann s BEPS Implications on Transfer Pricing Indian Perspective Comprehensive and Practical Guide with Analysis Case Studies Practical Strategies for Tax Professionals written by Ashutosh Mohan Rastogi and published by Taxmann Publications Private Limited. This book was released on 2024-07-09 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book offers a comprehensive and practical guide to understanding the intricate transfer pricing implications stemming from the Base Erosion and Profit Shifting (BEPS) project within the Indian context. This work culminates two years of extensive research and analysis by a team of transfer pricing experts. The book covers a wide range of topics, starting with an overview of the BEPS project and its objectives. It also includes an analysis of international rulings on BEPS, examining landmark cases and their implications for the transfer pricing landscape. This comprehensive guide is invaluable for tax practitioners, professionals, academics, and business leaders aiming to understand the impact of BEPS recommendations on transfer pricing in India. It facilitates informed discussions on this critical area of taxation and its implications for businesses operating in India. The Present Publication is the Latest Edition, authored by Ashutosh Mohan Rastogi, with the following noteworthy features: • [Realignment of Transfer Pricing Norms] The book explains why BEPS realigned 'Transfer Pricing' norms, illustrated through case studies of Google, Starbucks, and Apple, highlighting their implications on BEPS • [Understanding and Application of BEPS Action Plans] BEPS Action plans have transformed how Transfer Pricing concepts are understood and applied, shifting focus from titles and contracts to functions and risks. This book helps readers understand these nuances in the post-BEPS era • [BEPS Insights on Indian Law] Each chapter provides BEPS insights on Indian Law, discussing BEPS Action plans with reference to Indian Regulations, Circulars, and Case Law and explaining the relevance and implications of BEPS Action points in the Indian context • [Planning for Intangibles in the Post-BEPS World] The book decodes how to attribute profits to intangibles in the BEPS era, explains 'Development, Enhancement, Maintenance, Protection and Exploitation' (DEMPE) functions, and assesses the relevance of holding companies in low-tax havens today • [Economic Ownership] Readers will learn about the importance of Economic Ownership and how it is determined, exploring how Indian law attributes intangible returns based on legal or economic ownership • [Substance in Transfer Pricing] The book discusses the role of substance in Transfer Pricing, exploring whether Transfer Pricing officers can look beyond agreements to uncover reality and the role of significant people functions • [Benchmarking for Financial Transactions] It provides insights on benchmarking for financial transactions such as inter-company loans and guarantees, highlighting the importance of credit rating in financial transaction analysis and how to compute a credit rating • [Location Savings] The book explains where location savings should be taxed and whether profit split is the correct methodology for taxing location savings • [Defending Management Charges] It guides Multinational Enterprises (MNEs) on defending management charges, the availability of Safe Harbour for Management Charges in India, and the shortcomings of the safe harbour • [Cost Contribution Agreements] Readers will understand what cost contribution agreements are and how they differ from intra-group service agreements • [International Rulings on BEPS] The book summarizes leading international rulings on BEPS with illustrations, helping readers understand their implications and how tax litigators can apply them in the Indian context • [Three-Tier Documentation with FAQs] From the evolution and objectives behind the three-tier approach to the requirements suggested by the OECD and their adoption into Indian legislation, the book covers it all. It includes various prescribed templates and answers to general and transaction/issue-specific FAQs addressed by the OECD in the BEPS Action Plan 13 report The detailed contents of the book are as follows: • [Introduction] o This chapter provides an overview of the BEPS project and its objectives, including case studies of companies like Starbucks, Google, and Apple, illustrating the necessity for the BEPS initiative • [BEPS Implications on Transfer Pricing] o This chapter provides an in-depth examination of BEPS implications on transfer pricing, focusing on fundamental changes proposed by the OECD and their potential impact on MNEs in India. It analyses concepts such as economic substance, substance over form, and profit shifting to low-tax jurisdictions • [DEMPE Analysis] o This chapter provides a detailed discussion of the DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) functions, highlighting the complexities of attributing profits to intangible assets and the Indian tax authorities approach to these challenges • [BEPS Guidance on 'Substance over Form'] o This chapter discusses the principle of prioritizing economic substance over contractual form, emphasizing the importance of actual business activities and behaviours in determining transfer pricing as per BEPS guidelines • [Low-Value Intra-Group Services] o This chapter examines BEPS guidelines for low value-adding intra-group services, providing simplified approaches for determining arm's length charges and outlining documentation requirements for these services • [Financial Transactions] o This chapter analyses the intricacies of transfer pricing for financial transactions. This chapter covers treasury functions, credit risk assessment, inter-company loans, and guarantees, with an emphasis on compliance with the arm's length principle • [Cost Contribution Arrangements] o This chapter explores the concept of cost contribution arrangements (CCAs) under BEPS, discussing how MNEs share the costs and benefits of joint development activities and the implications for transfer pricing • [Location Savings] o This chapter provides an analysis of location savings and location-specific advantages, offering guidance on how these factors should be incorporated into transfer pricing strategies, particularly in the Indian context • [Three-Tier Documentation] o This chapter provides a review of the BEPS-recommended three-tier documentation approach, including the master file, local file, and country-by-country report, and a discussion on how these documentation requirements are implemented in India • [Dispute Resolution Mechanism] o This chapter discusses the mechanisms for resolving transfer pricing disputes, including the mutual agreement procedure (MAP) and India's Advance Pricing Agreement (APA) program. It provides practical insights into navigating disputes under the new BEPS regime • [International Transfer Pricing Rulings on BEPS] o This chapter summarises significant international transfer pricing rulings related to BEPS, offering key takeaways and their implications for the Indian transfer pricing landscape • [Conclusion] o This chapter concludes by synthesizing the key insights and practical guidance provided in each chapter, reinforcing the importance of understanding and applying BEPS principles to transfer pricing in India
Download or read book The Transfer Pricing Law Review written by Steve Edge and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Administration 2021 Comparative Information on OECD and other Advanced and Emerging Economies written by OECD and published by OECD Publishing. This book was released on 2021-09-15 with total page 355 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.
Download or read book Current Challenges in Revenue Mobilization Improving Tax Compliance written by International Monetary Fund and published by International Monetary Fund. This book was released on 2015-01-29 with total page 81 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper addresses core challenges that all tax administrations face in dealing with noncompliance—which are now receiving renewed attention. Long a priority in developing countries, assuring strong compliance has acquired greater priority in countries facing intensified revenue needs, and is critical for fairness and statebuilding. Series: Policy Papers
Download or read book International VAT GST Guidelines written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper set forth internationally agreed principles and standards for the value added tax (VAT) treatment of the most common types of international transactions, with a particular focus on trade in services and intangibles. Its aim is to minimise inconsistencies in the application of VAT in a cross-border context with a view to reducing uncertainty and risks of double taxation and unintended non-taxation in international trade. It also includes the recommended principles and mechanisms to address the challenges for the collection of VAT on crossborder sales of digital products that had been identified in the context of the OECD/G20 Project on Base and Erosion and Profit Shifting (the BEPS Project).
Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 378 pages. Available in PDF, EPUB and Kindle. Book excerpt: The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.
Download or read book Taxmann s International Financial Management Text Cases Detailed treatise of important concepts practical application with solved examples both numerical theoretical case studies etc written by Prof. Madhu Vij and published by Taxmann Publications Private Limited. This book was released on 2021-12-10 with total page 21 pages. Available in PDF, EPUB and Kindle. Book excerpt: International Financial Management provides an effective and detailed presentation of important concepts and practical application in today’s global business environment, which includes: • Foreign Exchange Market • International Financial System • Eurocurrency Market • Currency Futures & Options • Swaps • Country Risk Analysis • Capital Budgeting The key highlight of this book is that it uses several examples (both numerical & theoretical) to highlight the applications of various dimensions of international finance. This book aims to fulfil the requirement of students of PGDM, MBA, M.Com., Master of Economics, Master of Finance & Control (MFC), MIB, other Post Graduate Diploma in Risk Management & other post-graduate specialized disciplines. The Present Publication is the 4th Edition, authored by Prof. Madhu Vij. The book has been organized around five major areas, namely: • [International Financial Environment] emphasizing its institutional set-up while discussing why is it important to study international finance. This area is further subdivided into four chapters, namely: o Overview of the International Financial Management o History of International Monetary System; Emphasis on Bretton Woods System o International Financial Institutions with a particular focus on the World Bank, International Monetary Fund (IMF), and European Monetary System o Balance of Payment Concepts and Accounting • [The Foreign Exchange Markets] o Derivatives o Foreign Currency Futures and Options Contracts that are traded on Stock Exchanges o Forex Markets with an emphasis on Fundamentals of Forex Trading, Overview of Operations of the Spot and Foreign Exchange Markets, How is Foreign Exchange Quoted and Traded Worldwide • [Managing Foreign Exchange Exposure] o Management of Foreign Exchange Risk with a discussion on kinds of exposure MNCs face o Translation Exposure or Accounting Exposure, which discusses the various methods for translating financial statements o Management of Transaction Exposure that arises from contractual obligations denominated in a foreign currency o Management of Economic Exposure • [Financial Management of the Multinational Firm] o Foreign Direct Investment o Cost of Capital and Capital Structure of the MNC o Application and Interpretation of MNC Capital Budgeting explaining various methods with the help of numerical examples and case studies o Multinational Cash Management o Identifies and Analyses the Various Dimensions of Country Risk Analysis o Eurocurrency and Eurobond Market • [Managing Foreign Operations] o Interest Rate and Currency Swaps explaining how they can be used to reduce financing costs and risks o Global Depository Receipts and American Depository Receipts
Download or read book Navigating the Headwinds written by Mansi Kedia and published by . This book was released on 2014 with total page 150 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Latin American Economic Outlook 2019 Development in Transition written by OECD and published by OECD Publishing. This book was released on 2019-09-27 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Latin American Economic Outlook 2019: Development in Transition (LEO 2019) presents a fresh analytical approach in the region. It assesses four development traps relating to productivity, social vulnerability, institutions and the environment.
Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations written by Organisation for Economic Co-operation and Development and published by Organisation for Economic Co-operation and Development. This book was released on 1995 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt: Includes 1999 update. 1998 update in back.
Download or read book Combating Fiscal Fraud and Empowering Regulators written by Brigitte Unger and published by Oxford University Press. This book was released on 2021 with total page 369 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is an open access title available under the terms of a CC BY-NC-ND 4.0 International licence. It is free to read at Oxford Scholarship Online and offered as a free PDF download from OUP and selected open access locations. Combating Fiscal Fraud and Empowering Regulators analyzes the impact of new international tax regulations on the scope and scale of tax evasion, tax avoidance, and money laundering. These are analyzed through an ecosystem framework in which, similar to a natural ecosystem, new tax regulations appear as heavy shocks to the tax ecosystem, to which the 'species' such as countries, corporations, and tax experts will react by looking for new loopholes and niches of survival. By analyzing the impact of tax reforms from different perspectives--a legal, political science, accounting, and economic one--one may derive an assessment of the reforms and policy recommendations for an improved international tax system. The ultimate goal is to combat fiscal fraud and empower regulators, in that line, this volume is intended for a broad audience that seeks to know more about the latest state of the art in the realm of taxation from a multidisciplinary perspective. The money involved amounts to billions in unpaid taxes that could be better used for stopping hunger, guaranteeing education, and safeguarding biodiversity, hence making this world a better one. Regulators can see this book as a guiding light of what has happened in the past forty years, and how the world has and will continue to change as a result of it. Combating Fiscal Fraud and Empowering Regulators is also a warning about new emerging tax loopholes, such as freeports or golden passports and visas, where residency can be bought in tax havens, even within the European Union. The main message is that inequality can and has to be reduced substantially and that this can be achieved through a well-working international tax system that eliminates secrecy, opaqueness, and tax havens.
Download or read book International Taxation written by Nigam Nuggehalli and published by Springer. This book was released on 2019-11-26 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book covers all major topics in international tax law, ranging from permanent establishments and capital gains to the taxation of royalties and technical services, transfer pricing, and General Anti-Avoidance Legislation. It also highlights the Indian “story” of status vs. contract by examining four areas of controversy: permanent establishments, FTS (Fees for Technical Services) & Royalty, capital gains, and transfer pricing. The book approaches the subject of international taxation from two opposing yet related perspectives. One is the tax planning perspective, which involves contracts entered into by individuals and companies; the other is that of state regulation through increasingly complex legislation. The area of permanent establishments demonstrates the dominance of contracts over status, at least with respect to Indian tax law. However, some recent judicial decisions in this area demonstrate the susceptibility of contracts to status-related arguments. The areas of FTS & Royalty as well as those of capital gains and transfer pricing demonstrate the Indian government’s attempts to establish, through legislation, the dominance of status over contracts. Whereas traditional textbooks on international tax law focus on the legal technicalities of tax legislation, this book provides tax scholars and lawyers with an understanding of tax planning and tax legislation side by side in each chapter, specifying the respective kind of actual or anticipated tax planning activity that in turn prompted a legislative response. As such, it offers readers a contextual and practical introduction to the complexities of international tax law, as well as an in-depth analysis of the latest debates and controversies in this area.
Download or read book FEMA Compounding Orders A Comprehensive Analysis written by Harshal Bhuta and published by Bloomsbury Publishing. This book was released on 2021-05-15 with total page 800 pages. Available in PDF, EPUB and Kindle. Book excerpt: About the book The law governing exchange control aspects of cross border transactions viz. Foreign Exchange Management Act, 1999 along with its Rules and Regulations, is a special and unique statute in itself, which is regulated and administered by Reserve Bank of India ('RBI'). RBI implemented a policy decision in May 2016, to make public disclosure of all compounding orders passed by it. This has offered an ideal opportunity to gain insights into RBI's outlook and interpretation of FEMA, and also the administrative practices adopted by RBI from time to time. The book provides a comprehensive analysis of all the compounding orders published by RBI during the period July 2016 to December 2018, to facilitate FEMA practitioners, companies and other persons undertaking cross-border transactions in understanding the RBI's perspective which is the driving force behind its interpretation and administration of FEMA. Key features of the book · Solitary publication on analysis of RBI compounding orders (covering orders issued upto 31st December 2018) · Coverage of 1268 FEMA compounding orders · Arrangement of compounding orders Notification-wise and Regulation-wise · Handy comparison of erstwhile and revised FEMA Notifications for provisions contravened under the compounding orders · Vital insights into principles applied by RBI while interpreting provisions of FEMA and important notifications · Detailed reporting of nearly 100 compounding orders along with analysis and summary compilation of all remaining orders
Download or read book Exploring Residual Profit Allocation written by Sebastian Beer and published by International Monetary Fund. This book was released on 2020-02-28 with total page 51 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schemes of residual profit allocation (RPA) tax multinationals by allocating their ‘routine’ profits to countries in which their activities take place and sharing their remaining ‘residual’ profit across countries on some formulaic basis. They have recently and rapidly come to prominence in policy discussions, yet almost nothing is known about their impact on revenue, investment and efficiency. This paper explores these issues, conceptually and empirically. It finds residual profits to be substantial, but concentrated in a relatively few MNEs, headquartered in few countries. The impact on tax revenue of reallocating excess profits under RPA, while adverse for investment hubs, appears beneficial for lower income countries even when the formula allocates by destination-based sales. The impact on investment incentives is ambiguous and specific both to countries and MNE groups; only if the rate of tax on routine profits is low does aggregate efficiency seem likely to increase.
Download or read book Principles of International Taxation written by Lynne Oats and published by Bloomsbury Publishing. This book was released on 2021-09-30 with total page 709 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.
Download or read book Tax Morale What Drives People and Businesses to Pay Tax written by OECD and published by OECD Publishing. This book was released on 2019-09-11 with total page 68 pages. Available in PDF, EPUB and Kindle. Book excerpt: Unlocking what drives tax morale – the intrinsic willingness to pay tax – can greatly assist governments in the design of tax policies and their administration, particularly in developing countries where compliance rates are low. This report builds on previous OECD research to identify some of the key socio-economic and institutional drivers of tax morale across developing countries, and seeks to test for evidence of the social contract by examining the impact of public services on tax morale. It also uses new data on tax certainty as an entry point to explore tax morale in businesses, where existing research is very limited. Finally, the report identifies a range of factors related to the tax system that may affect business decision making, how they vary across regions, and suggests some areas for future research. Overall, the report provides a range of suggestions for further work, and how tax morale considerations can be integrated into holistic tax compliance strategies.
Download or read book Africa s Development Dynamics 2018 written by African Union Commission and published by Org. for Economic Cooperation & Development. This book was released on 2018 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This first edition explores the dynamics of growth, jobs, and inequalities. It proposes ten decisive actions to promote sustainable economic and social development and to strengthen institutions in Africa.
