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India Archive

  • December 2014

    Despite progress, Indian tax professionals say GST by 2016 is ‘close to impossible’

    December 18, 2014

    Even if Arun Jaitley succeeds in tabling a bill in parliament by the end of the year to introduce national GST in India, tax professionals say the government’s 15 month time frame for introducing the tax on April 1 2016 is not viable.

  • India: Ruling on applicability of deduction non-discrimination clause

    December 16, 2014

  • Recent transfer pricing decisions in India: The road ahead

    December 16, 2014

    The Indian State Supreme Court (Bombay High Court) has issued two important verdicts concerning Vodafone and Shell.

  • Taxing taxis: GST may cause Uber confusion for e-commerce companies in India

    December 12, 2014

    A Bill amending the taxing rights of the states and central government is rumoured to appear in the winter session of India’s parliament. This reallocation of taxing rights, however, will cause technology companies who may be liable for services tax in India to reassess their tax positions.

  • Ashok Lahiri heads up new committee on Indian tax and trade

    December 04, 2014

    In his Budget Speech 2014-15, Indian Finance Minister Arun Jaitley announced the setting up of a committee to interact with trade and industry and ascertain areas where greater clarity on tax laws is required.

  • November 2014

    India advised not to appeal Vodafone ruling

    November 27, 2014

    India’s top lawyer has advised his government not to appeal the Rs 3,200 crore ($525 million) Bombay High Court (HC) transfer pricing decision in favour of Vodafone.

  • H Raghavendra Rao joins Lakshmikumaran & Sridharan from BMR Advisors

    November 24, 2014

    Indian law firm Lakshmikumaran & Sridharan has confirmed that H Raghavendra Rao is joining the firm as the country head and leader of the direct tax practice. Rao spent nine years working for BMR Advisors as a legal senior advisor, following work at the Income Tax Department as a standing counsel before the Karnataka High Court.

  • Mitsubishi wins big for Japanese trading companies in Indian Berry ratio transfer pricing case

    November 20, 2014

    Mitsubishi Corporation India’s victory over the Indian tax authorities in the New Delhi Tax Tribunal on the use of the Berry ratio (gross margin divided by operating expenses) sets important precedents for transfer pricing litigation in India, advisers believe, because it legitimises the use of this method for determining profit levels and recognises the importance of business models in transfer pricing decisions.

  • Indian Parliament’s winter session to agree upon GST implementation

    November 05, 2014

    The long-awaited goods and services tax (GST) is very likely to be discussed in the Indian Parliament’s winter session, and the tax could be introduced in April 2016.

  • India's FATCA future unclear after names of alleged tax evaders are made public

    November 05, 2014

    On October 27, the Indian government disclosed names of alleged tax evaders to the Indian Supreme Court in an affidavit signed by the Department of Revenue. The affidavit accused some of the country's top business owners of tax evasion through foreign held bank accounts. This development raises questions over confidentiality clauses in FATCA agreements and other information exchange provisions.

  • October 2014

    Indian dispute resolution: Arbitration under bilateral investment treaties

    October 31, 2014

    Complex tax disputes have been a common occurrence in India for years. Foreign investors in India may have another legal strategy for trying to resolve such disputes: arbitration under bilateral investment treaties (BITs).

  • International Tax Review at 25: What has changed in a quarter of a century

    October 30, 2014

    Tax has changed dramatically since the first issue of International Tax Review came out in November 1989. Using a selection of articles – one from each year – Ralph Cunningham and Matthew Gilleard assess how many of those changes have been reflected in the publication over the past 25 years.

  • India: Ruling on characterisation of surplus on sale of debentures

    October 30, 2014

  • Microsoft wins Delhi appellate decision on service tax exemption for marketing services

    October 24, 2014

    The third member of the Delhi Custom Excise & Service Tax Appellate Tribunal (Cestat) has sided with Microsoft Corporation Pvt Ltd, the taxpayer, in its appeal against an adjudication order from the commissioner of service tax.

  • Bombay High Court rules in favour of Vodafone on share issue

    October 10, 2014

    In a decision that could give relief to more than 20 other pending cases, the Bombay High Court has ruled in favour of Vodafone that in the absence of income, a share issue transaction cannot be subjected to transfer pricing.

  • OECD unveils plan for 2014/2015 BEPS work

    October 02, 2014

    The OECD is getting straight back to work on base erosion and profit shifting (BEPS).

  • Treaty definitions proving a headache for Indian taxpayers

    October 01, 2014

    Differing tax treaty definitions, or the lack of them, mean that the term ‘operation of ships/aircrafts in international traffic’ has caused controversy for India’s taxpayers, explain Ajit Kumar Jain, Kanchana Ramamurthi and Mehul Jain of BMR & Associates.

  • India: Ruling on taxation of indirect transfer

    October 01, 2014

  • September 2014

    OECD BEPS reports – An Indian perspective

    September 30, 2014

    After the release of the OECD’s first set of reports and recommendations related to its base erosion and profit shifting (BEPS) project, Rajendra Nayak and Shweta Pai of EY provide an update on the implications of the reports from an Indian perspective.

  • G20 tax agenda is not all about BEPS

    September 26, 2014

    The G20’s finance ministers have outlined their plans to minimise global tax avoidance and evasion, which are not only about completing the work of the BEPS Action Plan on time by the end of next year.

  • The BEPS project at halfway

    September 16, 2014

    In this exclusive article for International Tax Review, Pascal Saint-Amans and Raffaele Russo of the OECD explain how the first half of the BEPS Project's work starts the task of bringing coherence, substance and transparency to international tax rules around the world.

  • The tax market reacts to the BEPS 2014 deliverables: Do you agree?

    September 16, 2014

    The OECD today unveiled its 2014 deliverables at the halfway stage of the multilateral organisation’s ambitious base erosion and profit shifting project, commissioned by the G20, which represents the biggest ever review of international tax rules.

  • World's leading tax controversy advisers unveiled

    September 05, 2014

    The fourth edition of International Tax Review's Tax Controversy Leaders guide is out now. Find out who the top-rated disputes specialists are in your jurisdiction.

  • India: Central and state governments struggle to reach consensus over GST

    September 03, 2014

    Arun Jaitley, Indian Finance Minister, has stressed that too many products cannot be excluded from the goods and services tax, as state governments push to keep products such as petrol, tobacco and alcohol outside the scope of the tax.

  • ONE adds to pressure on G20 to act against tax evasion and other illegal financial flows

    September 03, 2014

    The ONE campaign describes corruption involving developing countries as the $1 trillion scandal and says the G20 must implement measures such as automatic information exchange (AIE) and the transparent publication of the revenues governments receive if the organisation wants to end it.

  • August 2014

    World Tax Authority: Taking harmonisation to the next level

    August 29, 2014

    Recent attempts at tax harmonisation have struggled to take off. In Europe enhanced cooperation measures are being invoked because of the inability to find consensus. But what fate awaits the notion of a World Tax Authority (WTA)? Would it take tax harmonisation to the next level or, like the Europe-wide language of Esperanto, is this attempt at harmonisation doomed to fail? Matthew Gilleard analyses what has motivated discussion of such a concept and looks at the barriers to implementation.

  • Convergence or divergence: New reporting standards in India

    August 29, 2014

    India has announced the adoption of IFRS converged standards for financial reporting and tax accounting standards for the computation of taxable income. Sai Venkateshwaran, partner and head of the accounting advisory services group at KPMG in India analyses the impact and challenges of these announcements.

  • Alternative dispute resolution: Alleviating burdens all round

    August 29, 2014

    The number of tax disputes is increasing rapidly around the world. The trend is encouraging governments to turn to alternative dispute resolution (ADR) in a bid to reduce backlogs in the courts. While ADR is well established in some jurisdictions, in others it is just getting going. Aaran Fronda looks at how ADR has become an increasingly viable solution for resolving tax disputes.

  • The IMF and international tax

    August 29, 2014

    David Spencer, of the Law Offices of David Spencer in New York, analyses the recent work of the International Monetary Fund (IMF) and assesses its growing influence in the area of international taxation.

  • India: Ruling on availability of treaty benefits to a non-beneficial owner recipient

    August 29, 2014

  • UN survey calls for more tax cooperation in Asia

    August 29, 2014

    A UN body has highlighted the prospects of tax harmonisation and the elimination of tax competition in Asia-Pacific as methods for helping countries in the region to increase the amount of taxes they raise.

  • Indian High Court provides relief for indirect transfer of Indian assets

    August 28, 2014

    The Delhi High Court’s ruling in the Copal Research Limited, Mauritius case is the first on the taxation of the indirect transfer of Indian assets since the previous government’s much talked about amendment following the Supreme Court’s Vodafone decision.

  • Indian taxpayers get more time to file tax audit reports

    August 22, 2014

    The Central Board for Direct Taxes (CBDT) in India has given taxpayers an extra two months to file their Tax Audit Report (TAR) for the Assessment Year 2014-2015 because of changes it made in July to the forms required. However, there is no extension for the filing of income tax returns, which are still required by September 30.

  • India: High Court rules CCDs are exempt under India-Mauritius DTAA

    August 14, 2014

    The Delhi High Court has decided, in Zaheer Mauritius vs Director of Income Tax, that the sale of compulsory convertible debentures (CCDs) should be classified as capital gains and exempt under the India-Mauritius double tax treaty (DTT). The decision will mean most to real-estate taxpayers who use Mauritius to invest in India.

  • July 2014

    OECD answers your questions about the global automatic exchange standard

    July 24, 2014

    EXCLUSIVE: On Monday July 21 the OECD released the full version of the Standard for Automatic Exchange of Financial Account Information in Tax Matters, which requires financial institutions to report detailed financial account information to their governments, which then exchange such information automatically with other jurisdictions on an annual basis. The Standard developed by OECD in response to a mandate by the G20 was first presented to and endorsed by the G20 Finance Ministers in February 2014.

  • Have your say on ITR's development

    July 14, 2014

    The new website went live in late May. Take the opportunity to influence how it develops by completing our survey.

  • India’s convergence with IFRS is back on track

    July 11, 2014

    Arun Jaitley, the Indian finance minister, announced in his first budget yesterday that Indian companies will adopt new Indian Accounting Standards in line with International Financial Reporting Standards (IFRS) over the next three years.

  • India Budget: FM Jaitley wants GST by end of year

    July 10, 2014

    Arun Jaitley, Indian finance minister, wants to end continuing uncertainty surrounding the implementation of the goods and services tax (GST) by introducing the regime by the end of this year.

  • Pro-business Jaitley makes right noises in Indian Budget, but concrete action lacking

    July 10, 2014

    Delivering his first Budget speech today, Arun Jaitley, India’s new finance minister, pledged to maintain a stable tax environment, but disappointed multinational taxpayers by not removing rules on retrospective tax. Indeed, while the majority of the finance minister’s proposals sound business-friendly enough, taxpayers would have liked more concrete detail.

  • How Indian indirect tax laws align with OECD guidelines

    July 09, 2014

    India should strive to ensure that its indirect tax laws are aligned with the OECD’s VAT guidelines, believe Abhishek Jain and Saurabh Agarwal of EY.

  • India: Odisha’s state government demands green tax on mining to compensate for GST

    July 09, 2014

    State finance minister requests a green tax to be imposed on mining because he fears the destination principle, which forms part of the goods and services tax (GST) regime, will negatively impact revenue streams of mineral rich states.

  • COMMENT: The IMF's new paper on spillovers - time to rethink the rules for developing countries

    July 03, 2014

    The IMF has stirred up the debate on the global tax system in an important new staff paper, "Spillovers in International Corporate Taxation", which quantifies the knock-on effects of tax competition and shows that the tax bases of developing countries are particularly badly hurt by it.

  • BEPS and the digital economy: Why is it so taxing to tax?

    July 01, 2014

    Devising appropriate rules for the taxation of the digital economy is one of the most awkward challenges governments have set for themselves in the BEPS project, especially when defining the digital economy is an issue in itself. Aaran Fronda looks at the possible outcomes of the discussion.

  • In search of harmony: Finding a consensus on hybrid mismatches

    July 01, 2014

    Mismatches create opportunities. This is true in any scenario, whether it is the opportunity for a fleet-footed and nimble winger to gain an advantage by exposing the bulky, flat-footed front-row rugby forward who has temporarily become his opposite man, or whether it is in the (equally ruck-filled) field of tax planning. Matthew Gilleard looks at where the OECD is drawing the line when it comes to activity that takes advantage of tax law mismatches in an intended or acceptable manner, and that which is not.

  • Transfer pricing risk management: A case for APAs

    July 01, 2014

    Victor Adegite of KPMG Nigeria looks at the advance pricing agreement (APA) option as a tool taxpayers can use as part of their transfer pricing risk management, highlighting the benefits of different types of APA and looking at how APA programmes operate in other jurisdictions.

  • India: Ruling on seconded employees creating Service PE in India

    July 01, 2014

  • June 2014

    Indian FM Jaitley steps back from Vodafone tax disputes

    June 26, 2014

    Arun Jaitley, the Indian finance minister, has delegated responsibility for oversight of the Indian tax disputes involving Vodafone because he advised the company on tax issues during his legal career.

  • Budget preview: Indian taxpayers expecting indirect tax clarity and GST rollout

    June 25, 2014

    Arun Jaitley, India’s new finance minister, delivers his first Budget speech at the beginning of next month and taxpayers in India, as well as potential foreign investors, are hopeful of a general simplification of the country’s indirect tax system and specific detail on the implementation of the goods and services tax (GST) regime.

  • Indirect Tax Leaders 2014 now available

    June 23, 2014

    The third edition of International Tax Review's Indirect Tax Leaders' Guide, is all about identifying the leading professionals in this field, which is only increasing in importance. Between its covers, you will find the names, and biographies in many cases, of the world's leading indirect tax practitioners, which were collected after an independent research process. It should give taxpayers confidence that if they decide to hire any of these individuals, they will be getting the best in the field.

  • Financial Services Focus 2014 now available

    June 17, 2014

    Ahead of the launch of International Tax Review's Financial Services Tax website, the annual publication on Capital Markets tax developments has been repositioned to offer a greater breadth of topical coverage for financial services taxpayers and their advisers.

  • India Budget preview: Retrospective amendments still most contentious issue for taxpayers

    June 12, 2014

    Newly-elected Indian leaders Narendra Modi and Arun Jaitley must use next month’s Budget to repeal the retrospective amendments brought in under the previous government if they want to provide businesses with the certainty and confidence to invest and grow.

  • CII urges Indian government to implement GST early

    June 05, 2014

    The business community has welcomed new prime minister Narendra Modi’s rise to power, and now the Confederation of Indian Industry (CII) is hoping his government will increase efforts to establish a goods and services tax (GST) to improve investor sentiment and help put the Indian economy back on track.

  • Clause in Indian DTAA encourages greater investment from Singapore

    June 02, 2014

    The limitation-of-benefit clause in the India-Singapore treaty, offers greater clarity and comfort for investors residing in the country, helping to make Singapore India's top source of foreign direct investment.

  • May 2014

    Asia tax directors do battle with lengthy in-tray

    May 27, 2014

    The two-day Asia Tax Forum covered a range of issues and countries, not just BEPS, including dispute resolution and anti-avoidance, transfer pricing and China’s VAT reforms, reports Ralph Cunningham.

  • Avoiding the snares of international tax structures

    May 27, 2014

    International business expansions can substantially increase the bottom line, but this outcome is largely dependent on establishing an efficient structure that helps to ensure financial success. Lee Sheehan, head of tax at Radius, looks at the importance of a clear strategy when setting up tax structures for specific business locations, and points out some of the landmines to avoid along the way.

  • Mammoth rise in tax audits worldwide

    May 23, 2014

    Tax audits have risen 73% worldwide, giving corporations around the world plenty to think about when it comes to having their tax affairs in order.

  • What foreign direct investors should look out for when using a limited liability partnership to come to India

    May 23, 2014

    The popularity of limited liability partnerships for investing in India means clarification on the tax and regulatory issues is required, believes Tirthesh Bagadia of Bagadiya & Jain

  • Vodafone and Nokia switch tactics in attempt to resolve Indian tax disputes

    May 22, 2014

    The telecoms multinationals have issued notices of arbitration in a bid to end lengthy tax litigation with India.

  • World Tax 2016 and World Transfer Pricing 2016: Research opens in May 2015

    May 21, 2014

    The research will start for the 2016 editions of World Tax and World Transfer Pricing in May 2015. Please watch this website closely for further information.

  • Multifaceted digital economy issues remain key BEPS concern for taxpayers

    May 20, 2014

    The increased diversification of the digitised economy presents a major challenge for BEPS initiatives. Lack of a permanent establishment (PE) had led to debate over where tax should be applied, even where a digital entity is not practising a tax avoidance strategy. The prospect of amended tax legislation to address this has raised concerns over the increased risk of double taxation, and a regulatory burden on multinationals.

  • Declaration commits OECD and other countries to automatic exchange of information

    May 07, 2014

    Taxpayers must get used to the Common Reporting Standard as the means for the introduction of automatic exchange of tax information around the world.

  • Indian High Court orders authorities to rethink Nokia sales tax demand

    May 02, 2014

    Nokia India has got some good news from its tax disputes in the region after the Madras High Court told the tax authority in the state of Tamil Nadu to review its Rs2,400 crore ($399 million) claim against the Finnish telecommunications company.

  • US updates FATCA list of intergovernmental agreements

    May 02, 2014

    The number of jurisdictions considered to have an intergovernmental agreement (IGA) in place with the US for the implementation of the Foreign Account Tax Compliance Act (FATCA) has passed 50.

  • April 2014

    According to plan? The world of tax planning is changing, but not as fast as everyone would like

    April 30, 2014

    The world of tax planning is like one big global tug o’ war being played between multinational companies and their advisers, tax authorities, supranational bodies and non-governmental organisations. Everyone has an interest in changing the international tax system. But with everyone pulling in different directions, the pace of change is frustrating for most.

  • Managing TP risks in Nigeria: The importance of proactivity

    April 30, 2014

    Nigerian transfer pricing rules are still in their relative infancy, but taxpayers must take adequate steps to prepare now if they are to effectively identify risk areas and plan with both the company policy and the prospect of audit in mind. Victor Adegite of KPMG Nigeria provides an overview and looks at what lessons can be learnt from experiences around the world.

  • India: Indian government proposes revised version of Indian Tax Laws

    April 30, 2014

  • Asia-Pacific tax managers rate consistency as highest priority

    April 17, 2014

    Consistency has displaced complexity and predictability as the most important tax factor driving investment decisions in Asia-Pacific. Reputational risk and tax planning, as well as BEPS, also featured as important considerations for respondents to a survey of tax executives.

  • Cross-border tax avoidance and evasion – A developing Asia perspective

    April 11, 2014

    Satoru Araki, of the Asian Development Bank, argues that more regional cooperation will help developing countries in Asia to contribute better to the discussion about changing international tax rules and to improve their tax administration capacity.

  • India: Shome reform committee report due next month

    April 10, 2014

    The Parthasarathi Shome-led Tax Administration Reform Commission (TARC) will next month release its first report since being set up to review existing tax administration mechanisms in India and make recommendations for improvement.

  • BMR hires indirect tax expert Rao

    April 08, 2014

  • Delhi Tribunal decision shows PE question depends on facts not law

    April 03, 2014

    The Delhi Tribunal has ruled against the taxpayer in another case which highlights the service permanent establishment (PE) clause of India’s double tax treaties.

  • Revised Indian DTC takes aim at Vodafone-style transactions

    April 02, 2014

    The Indian government has released a revised version of the Direct Taxes Code (DTC) for public comment. One provision that stands out is aimed at bringing indirect share transfer transactions into the tax net.

  • Indian transfer pricing changes take time to benefit taxpayers

    April 01, 2014

    Transfer pricing reforms, such as the introduction of safe harbour rules, have not reduced litigation or cut the compliance burden in India. And the government’s approach to the BEPS project could increase reporting requirements, explain Rajendra Nayak and Shweta Pai of EY.

  • March 2014

    The global harmonisation of exchange of information

    March 28, 2014

    Corporate tax reporting in an era of exchange of information is still uncertain, but, as Samantha Merle, Sumeet Hemkar and Katrina Dautrich-Reynolds, of Taxand explain, taxpayers can still take steps to prepare for the introduction of new regulations.

  • Operational TP: When tax function meets finance function

    March 28, 2014

    Frank Schoeneborn, head of global operational transfer pricing in the finance and accounting division at Merck Group with headquarters in Germany, looks at the practical problems in the implementation of operational transfer prices, illustrating the new tax risks stemming from these problems and showing how holistic management can be the solution.

  • India: Profit attribution to permanent establishments

    March 28, 2014

    Sanjay Sanghvi and Ashish Mehta of Khaitan & Co. analyse recent tax rulings dealing with the attribution of profits to permanent establishments, looking at what multinationals can do to avoid becoming embroiled in similar disputes in the future.

  • Special features - April 2014

    March 28, 2014

    Read this month's special features on tax technology and India.

  • India: Delhi High Court rules on constitution of permanent establishment in outsourcing arrangements

    March 28, 2014

  • BMR Advisors promotes six

    March 21, 2014

  • Bharti Airtel decision puts emphasis on transfer pricing principles in guarantee cases

    March 20, 2014

    The decision of the Delhi Income Tax Appellate Tribunal (ITAT) in the Bharti Airtel case should encourage other Indian taxpayers to apply commercial and transfer pricing principles to agreements concerning corporate guarantees and capital contributions to associated enterprises in India, practitioners have said.

  • Asian Development Bank steps in with help for tax administrators

    March 19, 2014

    Like other multilateral organisations, such as the IMF and the World Bank, the Asian Development Bank (ADB) has deepened its role in helping to build capacity in tax administrations and to train officials. Satoru Araki, a public management specialist at the ADB, tells International Tax Review how his organisation does it.

  • Asia Transfer Pricing Focus 2014 now available

    March 14, 2014

    Leading transfer pricing advisers from KPMG in Australia, China, Hong Kong, India, Indonesia, Japan, Korea, Malaysia, New Zealand, the Philippines, Singapore, Taiwan, Thailand and Vietnam bring you insights and advice from across the region.

  • BEPS is not the only concern for Asia’s tax executives

    March 10, 2014

    The G20 / OECD project on BEPS is likely to preoccupy tax executives over the next two years, even in jurisdictions that do not belong to either group.

  • Secondments to India: Beware of the tax traps

    March 05, 2014

    A number of widely different tax rulings on secondment arrangements for expatriate staff working in India can mean uncertainty for firms setting up in the country. Sudhir Nayak of Nexia International member firm SKP Group in India, discusses some of the recent controversies.

  • Narendra Modi helps secure future of GST in India

    March 03, 2014

    The prime ministerial candidate for India’s Bharatiya Janata Party (BJP) has helped bring about a political consensus on GST.

  • February 2014

    Chidambaram brings Indian DTC Bill back into focus

    February 28, 2014

    While this month’s interim Budget in India was merely a vote-on-account and went largely unheralded in the corporate tax world, Finance Minister Palaniappan Chidambaram did make pledges regarding the Direct Taxes Code (DTC) and goods and services taxation (GST).

  • Big fish: The world's leading transactional firms revealed

    February 26, 2014

    International Tax Review analyses the global M&A trends over the last year and highlights the leading firms in the field.

  • India: Ruling on payment for dedicated bandwidth taxed as royalty

    February 26, 2014

  • OECD standard makes progress towards automatic exchange of information

    February 13, 2014

    Global automatic exchange of financial account information got a step closer today after the OECD published its Common Reporting Standard.

  • Non-filing of income tax returns can bring prosecution, Indian Supreme Court rules

    February 07, 2014

    The Supreme Court of India in a recent judgment (Sasi Enterprises v Assistant Commissioner of Income Tax Criminal Appeal No 61/2007) categorically declared it is a taxpayer / assessee’s statutory obligation to file a tax return and non-filing is an action liable for prosecution.

  • Chidambaram hopes dashed on Indian DTC prospects

    February 06, 2014

    Palaniappan Chidambaram, India’s finance minister, said this week that the Direct Taxes Code (DTC) and goods and service tax (GST) Bills will not be passed in the current Parliamentary session, despite telling International Tax Review in December that he was hopeful of passing the heavily-delayed DTC Bill in the winter session.

  • OECD seeks increased tax transparency from multinationals

    February 06, 2014

    The OECD has released a discussion draft outlining its proposals on information that multinationals may be required to disclose to tax authorities about their global operations.

  • January 2014

    The dark side of transparency

    January 28, 2014

    Tax transparency is lauded as an unequivocal good. But is it really this clear-cut? Matthew Gilleard explores the negatives as he ventures into the dark side of transparency.

  • Special features - February 2014

    January 28, 2014

    Read this month's special features on Canada and Tax compliance.

  • Getting value from advisers: An in-house perspective

    January 28, 2014

    Patrick Connolly is an experienced senior in-house tax adviser who has spent the past 10 years in in-house regional tax roles covering Europe, the Middle East, Africa and the Asia/Pacific regions as well as head office tax responsibilities. He shares his views on getting the most value from the client/adviser relationship. Paul Dunne, national managing tax partner for KPMG New Zealand and the tax lead on a number of multinational clients, provides his response and comments.

  • India: The importance and evolution of substance

    January 28, 2014

    Taxpayers are aware that demonstrating substance in a given transaction is of paramount importance. Here, Sanjay Sanghvi and Aditi Mukundan of Khaitan & Co explain why this is even more relevant in India by exploring the evolution of the substance requirement in Indian tax law.

  • Tax, development and the new Millennium Development Goals

    January 28, 2014

    Seth Terkper, Ghana’s minister of finance, and Hafiz Choudhury, senior adviser, International Tax and Investment Centre, discuss the challenges for developing countries in creating tax systems that raise enough revenue to fund development and also encourage investment.

  • India: Ruling on eligibility of fiscally transparent entity for tax treaty benefits

    January 28, 2014

  • Indian tribunal rules on certain crucial aspects of tax penalties

    January 09, 2014

    The Income Tax Appellate Tribunal (ITAT) has in a recent ruling confirmed the levy of penalty on the offset of tax-exempt capital losses against taxable income in a finding that the claim of the taxpayer was not sustainable in law. In doing so, the ITAT has highlighted some crucial aspects of law concerning levy of tax penalties, explain Sanjay Sanghvi & Ashish Mehta of Khaitan & Co.

  • Ajit Tolani leaves ELP to set up own practice

    January 07, 2014

International Correspondents