Budget 2018 – International Taxation Expectations | simply inTAXicating

Budget 2018 - International Taxation Expectations | simply inTAXicating

International taxation along with Transfer Pricing continues to be a major area of disputes for the MNEs and the tax authorities. Although the CBDT has taken several steps such as APAs and Sea Harbour rules and detailed guidelines on indirect transfer but the taxpayers are looking for more clarity and they expect certain positive steps to be announced in the Budget 2018. TIOL invited four domain experts – Mr D P Sengupta, former CCIT; Mr Neeraj Jain, Partner, Vaish Associates; Mr M S Vasan, V-P, Hinduja Global Solutions and Mr Vishal Anand, Partner, PwC. The episode was moderated by TIOL Founder Editor, Mr Shailendra Kumar.

This episode of legal wrangle tracks major judicial developments in the world of international taxation. The First case discusses the treatment of overseas payment for specific service under technical assistance agreement; the second one is about the shifting of profit to foreign tax jurisdiction, in the garb of commercial expediency; and the third one discusses the taxability of income arising either directly or indirectly through representative of non-resident, from business connection in India. The cases features are as follows:

2018-TII-61-HC-MAD-INTL
MADRAS HIGH COURT
DIRECTOR OF INTERNATIONAL TAXATION, MADRAS Vs M/s TVS MOTORS COMPANY LTD
Date: October 24, 2018

2018-TII-584-ITAT-MUM-TP
MUMBAI ITAT
M/s EBAOTECH INDIA PVT LTD Vs DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI
Date: October 22, 2018

2018-TII-58-HC-KOL-INTL
CALCUTTA HIGH COURT
DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) Vs BOARD OF CONTROL FOR CRICKET IN SRI LANKA AND ORS THROUGH PILCOM
Date: September 25, 2018

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Krishanu Malik

Yaaaayyy sheenam!!! You look so serious. Dayummnnn. 😀

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