Tag - International tax

SCN-8 “CONTROLLED FOREIGN COPRORATIONS”

Hello Readers, Welcome to the SCN Series. Today's Term is CONTROLLED FOREIGN COPRORATIONS (CFC): It is an anti tax avoidance measure where a parent company opens a subsidiary in low tax jurisdiction and then evade the tax by non distribution of dividend or profits to the shareholders of parent company. Here it is..... Controlled Foreign Corporations (CFCs) are corporate entities incorporated in an overseas low tax jurisdiction and controlled directly or indirectly by residents of a higher tax jurisdiction (Parent State). Since each corporate entity [...]

SCN-6 “CbC REPORTING”

Hello Readers. Welcome to the SCN Series. Today's term is from International Taxation part of the Income Tax: CbC Reporting: In order to prevent tax avoidance, Multinational Enterprises (MNEs) whose consolidated revenue of International Group is more than Rs. 5,500 crores (as reflected in the consolidated financial statements for the preceding accounting year) are required to report to the income tax department annually for each tax jurisdiction (each country) in which they do business the information set out therein. This reporting is called the Country-by-Country (CbC) Reporting. Click here for the [...]

SCN-1 “Tax Treaty”

Hello Readers, Starting with the first concept of this series: Tax Treaty Also known as a Bilateral Agreement, A tax treaty is a bilateral agreement signed between two nations so as to prevent the issues of double taxation on income. As per this agreement, both the nations decide the rates of tax that has to be applied to an income of a person in both the nations i.e. country of origin of income and the home country. Sometimes, it is in the form of [...]

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 [...]

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 – 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 [...]

A brief Study on International Taxation

International Tax is best regarded as the body of legal provisions of different countries that covers the tax aspects of cross – border transactions. It is concerned with Direct Taxes and Indirect Taxes – Kevin Holmes INTRODUCTION: International taxation in a simple language means the study of Taxation beyond the National Level. Though we all are very much aware about our Indian Taxation Laws but as time is demanding something more so, there is a need to study the taxation at [...]

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