India
As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic
If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues
Increasingly, clients are looking for different advisers to the established players, Ryan’s president for European and Asia Pacific operations tells ITR
Foreign remittance requirements put additional administrative burden on Indian law firms and strain their relationship with foreign associate firms, according to practitioners
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Sponsored by Dhruva AdvisorsThe Income-tax Act, 1961 was amended in 2012 such that non-resident taxpayers are not entitled to claim relief under a tax treaty unless they obtain a tax residency certificate (TRC) from their country of residence. But a recent court ruling has changed the situation. -
Sponsored by Dhruva AdvisorsLitigation in respect of when a non-resident has a permanent establishment (PE) in India has always been a contentious issue.
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Sponsored by Dhruva AdvisorsRecently, the Income Tax Appellate Tribunal gave an important judgement regarding the creation of and attribution of profits to an agency permanent establishment (Agency PE) – Daikin Industries v ACIT ('ITA No 1623 of 2015 [New Delhi Income Tax Appellate Tribunal, May 28 2018]').
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