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Transfer Pricing and Intangibles – Value Analysis

Intangibles constitute a substantial and major portion of transfer pricing issues on hand. They are extremely crucial in a Multinational (MNE) environment, however, their importance is often undermined to their inherent characteristics which may include easy mobility, misidentification and most importantly non-availability of set principles to assign values to such intellectual properties. Supply Chain and […]

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Draft amendments in INDIAN Permanent Establishment rules – equitable or abstract?

Background India has touched upon the taxability of profits of Permanent Establishment (‘PE’) in its international tax treaties under ‘Article 7’. Currently, profits of PE are determined based on its books of accounts considering it as a separate and distinct entity or in case of non-preparation of the same, apportionment is to be done on […]

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Drafting a Transfer Pricing Policy

A quick and basic glance on how to draft a transfer pricing policy

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What is Global Transfer Pricing?

Transfer Pricing as a subject means undertaking global international transactions between the related parties (we call it associated enterprises), at a value which is as per the market conditions (Arm’s Length Price), so that the profit allocations between the countries is fair and appropriate. Due to the close relationships, there could be certain influences on […]

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The Story of Interim Budget – 2019

Snapshot of India’s development path The years gone by: With the reforms and positive changes brought about by the current Government, it is truly a golden age for the Indian economy. Ushering in stability in the nation, transformation in all sectors, cleanliness in pecuniary terms by demonetization as well as in literal terms through […]

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Angel Tax – Simplifying the tax life of a Start-up

A lot has been said about angel tax over the years. While the technocrats are well aware of the topic, most of the non-technical start-ups have no clue until they get a surprise from their VC, CA or a tax officer. Let us look at simplifying the topic and understand how some air of confusion […]

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Transfer Pricing – Gliding through the Fundamentals

What is ‘Transfer Pricing’? ‘Transfer Pricing’ is an art and science of determining the value of transactions that take place between entities of the same multi-national group. It involves the consideration of economic factors to perfectly balance a corporation’s and tax authority’s interest in terms of profitability and taxation. Why ‘Transfer Pricing’ in ‘Taxes’? Earlier, […]

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Build an effective career in Taxes

Till today, I have tried to give my views on the technical side of taxation and hope you have enjoyed. This time, I thought, it is important that the students of commerce, accountancy, finance, law and management understand what the studies in taxation have to offer to them that could give the young minds a […]

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Effective Tax Rate – The Mantra to successful tax management

Effective Tax Rate (ETR)

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5 Tips for effective Transfer Pricing Compliance

As the Indian transfer pricing compliance season is around the corner, I am sure, many multinational companies along with the Chartered Accounts would be occupied in justifying and certifying the transfer prices for the company undertaken in FY 2017-18. Here are the top 5 tips for an effective transfer pricing season for the MNC as […]

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Top 5 Best Taxation Practices

I have often seen many multinational organizations quoting the increase in top-line figures as an important indicator of growth for a company. Often the management forgets to focus on the bottom line (profits) and something that is below the bottom line (i.e.taxes). While you as an organization is growing at a fantastic pace in terms […]

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Is it compulsory for my foreign company to file Income tax returns in India…

Taxes are one of the funniest parts of serious business. They are sometimes uncertain, interpretative, dynamic or beneficial to a taxpayer (many more adjectives or attributes could be used). One tax and many forms, often make taxes as one of the complex subjects to understand. Even Albert Einstein laid down his arms before taxes and […]

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5 Finance secrets making your start-up attractive

The article provides a glimpse of financial aspects to be taken care while in start-up phase

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Intra-group service payments – Tax Risk Mitigation approach vs. Tax Litigation approach

In the globalised world, every multinational enterprise (MNE) would like to work on their strengths to enable efficient and successful supply chain management. In the current scenario, business is not only provision of goods and services to the ultimate external customer, but also provision of such goods and services to the internal customer. In a […]

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Critical Analysis – Google India – AdWord – Royalty Case

1. The case with regard to the Google AdWord by the Bangalore ITAT could be categorised as a judgement that could have far-reaching effects on the digital economy in India. The judgement and the interpretation of business scenario need to be understood simplistically removing all the technical jargons and marrying the facts of the case […]

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“In the Business of Making Loss” with special reference to taxation of the Flipkart deal

The energetic rise of multi-national e-commerce businesses: With the advent of internet a few decades ago, the online marketplace has gained an impetus in recent years, thereby revolutionizing the B2B, B2C and C2C transactions. As a consequence, the hassles of physical limitations, investment of time and boundaries among the nations have been eliminated. Such […]