UAE – CT Guide on Tax Return
The #UAE published a Corporate tax Guide - CTGTXR1 for taxpayers to aid them in filing of tax returns in the EmaraTax portal...
Intra-Group Services
Happy to share VSTN's recent article on “Demystifying Intra-Group services in Transfer Pricing” co-authored by Nithya Srinivasan...
Time for Transfer Pricing Compliances
TP compliance deadline of October 31 is fast approaching & companies to be ready for filing Form 3CEB...
UAE – TP Disclosure Form
UAE TransferPricing (TP) disclosure form is now enabled in the EmaraTax Portal. The taxpayers while filling...
Corporate Guarantee
VSTN's recent article on “Corporate Guarantee- A deep dive ” is coauthored by Nithya S and RS Chitra which was published in the CASC...
DTVSV 2024
The Finance Minister presented the full year Union Budget for 2024-25 on 23 July 2024. As a measure to address the rising number of pending...
Risk Indicators For TP Policy Design
HMRC UK issued Guidance for compliance (in 3 parts) on 10 Sep 2024 on common risks in TP approaches for MNE. Part 3 of the guidance sets...
Indian Safe Harbour Rules
VSTN's recent article is on “Understanding Safe Harbour Rules: An In-Depth Analysis” coauthored by Nithya Srinivasan and Krithika Valliappan...
Interest on Overdue Receivable
VSTN Article on “Interest on overdue receivables” coauthored by Nithya S and Ranjani S which was published in the “CASC Monthly Bulletin”...
UAE Corporate Tax Law
The United Arab Emirates (“UAE”) Ministry of Finance (MoF) issued the Federal Law on the Taxation of Corporations and Businesses by enacting...
Union Budget 2024
The full year Union Budget for 2024-25 was presented by the finance minister on 23 July 2024. VSTN alert summarizes the Transfer pricing updates viz...
FTA directive on APA- UAE (2)
The Federal Tax Authority (FTA) issued Decision No.4 of 2024, effective from July 01, 2024, which enunciates FTA’s policy on issuing clarifications & directives relating...
OECD Pillar 1 Guidelines on Amount B
Further to the report published on Amount B- a simplified & streamlined approach for application of arm's length principle to baseline marketing & distribution activities, OECD on Jun 17, 2024.....
APA Considerations with comments
Taxpayers, before deciding on APA, sometimes miss out on certain aspects which has to evaluated in advance through a feasibility study on the pros & cons. Key areas warranting consideration...
OECD update guidance on CbCR
Recently, the OECD had issued its updated guidance on Country-by-Country reporting. The May 2024 update is on treatment of dividend Table 1 of the Country-by-Country (CbC) report...
ICAP
OECD has recently published an updated document (FAQ) in respect of International Compliance Assurance Programme (ICAP/Programme) which commenced on September 2021....
KSA APA
The introduction of the APA program comes as a silver lining to the KSA Transfer Pricing tax regime. This welcome move demonstrates the proactiveness of the KSA Government...
Management charges
MNEs around the world endeavour to achieve economies of scale by centralising certain activities among the Group (i.e., IT, legal, payroll, back office, marketing, R&D, etc.,).
Aggregation of Transactions
Aggregation of transactions during benchmarking analysis has seen wide adoption without appreciating the nuances of transactional analysis. Though various country regulations and OECD....
India APA – FY 23-24
The Ministry of Finance issued a press release yesterday, 16 April 2024, on the total number of Advance Pricing Agreement concluded in FY 2023-24 between CBDT and taxpayers. ....
HMRC Guidance on Risk
Delineation of transactions is foundational for determining the most appropriate TP method & analysis of risk is the bedrock for accurate delineation of transactions.
Amount B – Guidance
The OECD issued the final report on AmountB on 19 Feb 2024. These rules will form part of the OECD transferpricing guidelines and has been rechristened as the simplified ...
KSA RHQ Tax Rules V1
The Zakat, Tax & Customs Authority (“ZATCA”) recently published the Tax Rules, further to the RHQ program issued in December 2023 (link to previous alert in comment)...
KSA updates
January 01, 2024, marks the advent of certain key TP developments in KSA. Applicability of Transfer Pricing provisions for Zakat Payer, Kickstart of the Regional Headquarters (RHQ) regime...
UAE Tax Groups
The UAE Corporate Tax Regime introduced the concept of “Tax Groups” for Corporate Tax purposes. Though the concept of Tax Groups is not new as it already applies for VAT Regulations in UAE...
Safe Harbour Rules
The CBDT issued a notification on 19 December 2023 amending the existing safe harbour rules applicable from FY 2023-24. The alert captures in detail the amendments to the existing
Imputation of notional interest
Transferpricing adjustments of “Interest on overdue receivables” holds a prominent place in the list of adjustments carried out by taxauthorities. In a TP environment, long overdue receivables...
IOSR article
As part of VSTN ‘s thoughtleadership, glad to share that our researchpaper has been published with @IOSR Journals demonstrating 'core competence’ which is one of the Core pillars of VSTN..
UAE Transfer Pricing
Though uae corporatetax regime kick started from 01 June 2023, the Corporate Tax regulations will become applicable to many businesses who have Calendar Year as their accounting period ....
BEFIT TP
On September 12, 2023, the European Union commission unveiled the much awaited proposal on “Business in Europe: Framework for Income Taxation” (“BEFIT”)
UAE Reccent Notifications
During August and September, The United Arab Emirates (“UAE”) Federal Tax Authority has published the below corporate tax guides with an intent to make the corporate tax ....
APA Annual report
The CBDT has recently released the 4th and 5th Advance Pricing agreement (APA) annual report for the period FY 2019-20 to 2021-22 and FY 2022-23 respectively.
Assessment issues in COVID year
October 2023 is an important month for Transfer Pricing with Form3CEB deadline as well as due date for completion of FY 20-21 TP assessment by TPO. This is also first full year impacted by COVID...
Safe Harbour – key consideration
OECD in its transferpricing (TP) guidelines (TPG) has stated Safe Harbour (SHR) as an administrative procedure to aid minimising TP disputes. SHR was introduced in India in 2013.....
OECD issues – Amount B of Pillar One
Following the consultation document issued in December 2022, the OECD / G20 Inclusive Framework (IF) issued public consultation document on AmountB -PillarOne ...
Cost Corporate Guarantee
Recently, DGGI has issued demand notices to various local corporate houses and MNCs in connection with CG given on behalf of their subsidiaries.
LIBOR to ARR – TransferPricing
LIBOR was phased out in December 2021, with final USD based LIBOR ceasing by 30 June 2023, following which financial instruments have to be priced on alternate reference rate (ARR)...
UAE Corporate Tax Update
The UAE Ministry of Finance issued three documents on Corporate Tax, last week. The Transfer Pricing aspects arising from these decisions are summarised below...
Malaysia TP Rules
Malaysia has replaced its existing Transfer Pricing rules with the New TP Rules, and this would be effective for the YA 2023 onwards. Additionally, a minimum TP...
VSTN AMP Post
One of the most controversial issues in the transfer pricing arena which started in the past decade was treating Advertisement , Marketing and Promotion (AMP) expenses...
UAE TP Limits
UAE MoF had released the much-awaited notification regarding the conditions for maintenance of TP documentation (Local file & Master file) in the form of Ministerial decision no. 97...
Corporate Guarantee (CG)
In light of the recent Mumbai Tribunal ruling – Macrotech Developers (Lodha ), the below post explores the technical aspects on CG. OECD Guidelines states a legally...
SC ruling sap labs
Last week, in a landmark verdict in the case of SAP Labs, the SC overturned the HighCourt ( HC ) order in the case of Softbrands.The SC ruled that HC has to decide...
Middle East TP Updates – UAE and KSA
The Zakat, Tax and Customs Authority of Kingdom of Saudi Arabia (KSA) has issued its directive in extending transfer pricing regulations and introducing advancepricingagreement (APA).....
UAE MSME Relief
Under the UAE Decree Law on Corporate Tax (Article 21- Small Business Relief) issued in December 2022, it was specified that a Taxable Resident Person may elect to be treated as not having derived....
Sale and leaseback of IP
Leaseback of tangible assets is a financing arrangement, mainly to freeup working capital as well to be the economic owner of the asset. Leaseback is an option/tool to divest certain risk.....
TP not a compliance
TP rules are part of the tax laws of any country but is more deeply connected with business interests having roots deeper into economic reality. It is often that TP is given importance ....
Country-by-Country Report (CbC)
As the due date for filing of CbC for applicable IndianHQ – FY 2021-22 (AY 2022-23) is approaching i.e., 31 March 2023, it is important...
TP ISSUES FOR ROYALTY TRANSACTION
In the attached article we have presented our analysis on royalty payment, which is a highly litigated transaction in the transfer pricing...
India Budget 2023 Proposals – TP
The Finance Minister presented the Union Budget for 2023-24. The alert captures the Transfer Pricing updates in the Finance Bill 2023 and includes...
Budget2023 Expectations
On 01 February 2023, the Finance Minister will present the budget for 2023. Transfer Pricing expectations / recommendations ...
Pillar One – Amount B
The OECD / G20 InclusiveFramework (IF) issued public consultation document on AmountB of PillarOne on 08 December 2022....
Master File – Practical considerations
MasterFile (MF) in Form3CEAA to be efiled by Indian entities of MNE Group by the due date of filing IT return i.e., 30 November. While Part A...
Structuring
One comes across situations, wherein first the promoters establish an entity (startup)in India. As they look to expand to foreign market , for ease...
MF and Cbc Notifications
While we prioritise on form 3CEB & TP documentation by 31 Oct 2022, one should not miss on filing two more forms related to transfer pricing...
Form 3CEB practical implications part 2
Interest free loan – Indian HQ has provided interest free loan to its AE, it needs disclosure & care to be taken in terms of its evaluation for ALP...
Form 3CEB practical implications
Identification of Associated Enterprises(AEs) – Information in Form 3CEB has to be certified to be true & correct as against true and fair position...
Defending Loss making companies
While preparing TP documentation, in instances where companies have incurred losses during the financial year, defending transfer prices using...
Transfer Pricing compliances timelines
As the individual tax return filing season has gone by, the next upcoming one would be for corporates. In case of companies not subject to transfer pricing...
Trueup Adjustment
As companies move towards closure of audit for FY 21-22, one of the critical aspects which would arise from the transfer pricing....
Form 3CEF Notification
On 16th July, 2022, the Directorate of Income Tax (Systems), New Delhi, has issued the notification where it has been prescribed that Form No. 3CEF which...
Safe Harbour Rules
The CBDT issued a notification on 19 December 2023 amending the existing safe harbour rules applicable from FY 2023-24. The alert captures in detail the ...
OECD issues Amount B report
The OECD issued the final report on Amount B on 19 Feb 2024. These rules will form part of the OECD transfer pricing guidelines and has been rechristened...
KSA – APA Program
The introduction of the APA program comes as a silver lining to the KSA Transfer Pricing tax regime. This welcome move demonstrates the proactiveness....
International Compliance
ICAP is a voluntary risk assessment & assurance process designed to be an efficient and effective tool to facilitate MNE Groups achieve...