Income Tax

International Taxation – FAR Analysis

Hello Readers, Hope you have read the previous parts. Click here to see the previous parts. FAR Analysis Functions, Assets and Risk (‘FAR’) analysis is an analysis of the functions performed, taking into account assets used and risks assumed by associated enterprises (AEs) in controlled transactions. A method of finding and organizing facts about a business in terms of the functions performed, assets used (including intangible property) and risks assumed by such business to: Identify how they are divided among the AEs; and Ø [...]

Become An Informer of Income Tax Dept. and Get Rewards up to Rs 5 Crore

The centre government has launched Income Tax Informants Reward Scheme, 2018, after superseding the 2007 award scheme, under which a person can get reward up to Rs 50 lakh for giving specific information about substantial evasion of tax on income or assets in India. Also, those informing the government about 'undisclosed black money' stashed abroad can win awards up to Rs 5 crore. Anyone who informs about Benami properties can get awards up to Rs 1 crore. The scheme comes [...]

International Taxation – Profit Level Indicators

Hello Readers, Hope you have read the previous parts. Click here to see the previous parts. Profit Level Indicators  A profit level indicator (PLI) is selected to test the profitability of tested party. PLIs are ratios that measure relationships between profits and costs incurred or resources employed. PLI should always have an untainted* base (denominator) like adopting cost as base for export transactions and revenue as base for import transactions. *A tainted income or expense would mean one that is received from an AE paid [...]

International Taxation – Computation of ALP

Hello Readers, Hope you have read the previous parts. Click here to see the previous parts. Let’s proceed further…. Computation of ALP: I had already discussed CUP method of computation of ALP, so now let us discuss other parts: Method 2: Resale Price Method The resale price method (RPM) is a method which compares the gross margins (i.e. gross profit over sales) earned in transactions between related and unrelated parties for the determination of the ALP. The RPM requires high level of functional comparability and [...]

International Taxation – Int. Transactions, Profit Shifting, ALP Computation

Hello readers, hope you have read the previous parts in which we had covered the basics of international taxation laws and the concept of associated & deemed associated enterprises. Let’s proceed further….. International Transaction An international transaction means: a transaction between two or more associated enterprises, either or both of whom are nonresidents; and transaction in the nature of: sale/ purchase/ lease of tangible property; or sale/ purchase/ lease of intangible property; or provision of services; or lending/borrowing money; or any other [...]

International Taxation – Associated Enterprises

Hello Readers, Yesterday we have discussed about the basics of international taxation and covered basic aspects regarding the Arm Length’s Price principles and the reason behind the introduction of transfer pricing provisions in the Income Tax Act, 1961. Hope you have gone through it. Let’s proceed further and today we will cover other aspects of transfer pricing. **TP means Transfer Pricing **ALP means Arm Length Price Section 92: COMPUTATION OF INCOME FROM TRANSACTION WITH NON-RESIDENT Section 92 provides that any income arising from an “international transaction” [...]

International Taxation – Basics

INTERNATIONAL TAXATION Why should a Chartered Accountant be aware of International Taxation Laws? In context of ICAI’s vision; The profession of Chartered Accountancy is touching international heights in the area of Auditing and Taxation. Our Institute is working relentlessly for making Indian Chartered Accountants, A Global Professional. Now what makes a Chartered Accountant different from other professionals is their adaptability towards new and tough areas. As you know very well, Taxation is the most dynamic and wide area as compared to [...]

Rule 6DD [Exception to Section 40A(3)]

Rule 6DD [Exception to Section 40A(3)]: Cases where CASH payment exceeding Rs. 10,000 is Allowed:- Salary of Employee after deducting TDS where, employee is temporarily posted greater than or equal to 15 days continuously at place (not place of duty) or ship & at that place, employee does not have any bank accounts. Terminal benefit upto Rs. 50,000 to employee. For general understanding: Terminal benefit is the last amount paid to employee either on termination or resignation or in other cases. Firstly we have [...]

THE PNB FRAUD

THE PNB FRAUD The hot topic of these days is PNB scam. Everyone is sharing on social platforms that PNB is involved in the fraud of Rs.  11,500 crores approx. but everyone is not aware about the way it has happened. So, let us discuss about the one of the biggest scams of the country, The PNB Fraud. **For the purpose of this article, Foreign Bank means “Foreign branch of an Indian Bank” Before proceeding further, we should know about the LoU i.e. [...]

Base Erosion & Profit Shifting – A Global Challenge

Base Erosion & Profit Shifting – A Global Challenge Meaning: “Recently more and more enterprises organised abroad by American firms have arranged their corporate structures aided by artificial arrangements between parent and subsidiary regarding intercompany pricing, the transfer of patent licensing rights, the shifting of management fees, and similar practices in order to reduce sharply or eliminate completely their tax liabilities both at home and abroad.” So, Base erosion and profit shifting (BEPS) refers to tax avoidance strategies that exploit gaps and [...]

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