Status check of OECD's BEPS Project
Strengthening CFC Rules to counter BEPS
Tax Justice Issues in Africa and impact of BEPS
OECD Instruments are merely a policy consideration?
Emerging trends on Financial Transaction in TP

Preventing artificial avoidance of PE
Tax challenges in Digital Economy 
BEPS and intangibles 
Taxation of liaison office and BEPS
Google tax and completion of BEPS project

Modify Bilateral Tax Treaties through Multilateral Instrument
New dimensions of Cost Contribution Arrangements
Losses/Low Profits & Transfer Pricing
Extended Powers of TPO in Action
Outbound Investment - Managing Indian Tax and Transfer Pricing 
FATCA - Comprehensive reporting mandate
Asia Pacific Tax Authorities  - Matching  each other in aggression 
Section 206AA v/s DTAA - Who Rules?

BEPS - Action 7 - Measure to Counter steps of MNCs to artificially preventing PE status
BEPS - Action 8 - Hard-to-value intangibles
Transfer Pricing - Are HO and Branch covered for TP?
AOP - A never ending tax dispute
Section 44BB - SC provides relief to non-resident service providers
Limitation of Tax Treaty Benefits - Critical evaluation
Black Money Law
FATCA
e-Commerce Taxation
Foreign Tax Credit

Sales commission taxation for non-residents
Foreign Tax Credit - Issues
Place of Effective Management - Practical Issues
Withholding Taxes
        Deduction of tax on Overseas Head Office Expenses
        Mandatory reporting and CA certification of imports transactions
Permanent Establishment
Transfer Pricing

Place of Effective Management - International Perspective
MAT Relief to Foreign Companies - Whether discriminatory to Indian Companies?
OECD : The Principal Purpose Test
Transfer Pricing : High Margins In Comparability Analysis - An Unending Debate?
Permanent Establishment : Commissionaire Arrangements and PE Status

Taxation of Digital Economy and Virtual PE
Make in India - Transfer Pricing Considerations
Tax Challenges of an India CFO
Foreign Tax Credit - Practical issues
ALP for Non binding investment advisory agreement for foreign funds
Rollback of Advanced Pricing Agreements - Open issues
AMP expenses - A new era has just begun
Trends in Transfer Pricing Litigation in 2015

APA Rollback rules Needs more clarity
AMP expenditure - Is the Dust settled
Capital Gains
Finance Bill, 2015
Withholding Tax
Investment in India
Tax Disputes
BEPS
Royalty
Fee for Technical Services
Place of Effective Management

Smooth Road to Investing in India
- Taxation of Foreign Investors
-Taxation of Indirect Transfers
- Taxation of Alternative Investment Funds
- Unearthing Black Money
- MAT Provisions
- Payment of interest by Indian Branch of a Foreign Bank
- Taxing PoEM
- Fund managers not to constitute a PE in India

Base Erosion & Profit Shifting : Action Plan 10: Low value adding intra-group services, Action Plan 15: Developing a multilateral instrument to modify Bilateral Tax Treaties, Transfer Pricing :  Judicial position on reporting an international transaction in Form 3CEB • Disputes in captive IT/ITeS space • Location saving - Eating savings of outsourcing.  Treaty Dispute Resolution : An initiative to establish a Permanent Tribunal for Treaty Arbitration. Industry Analysis : E-commerce: From Brick and Mortar to click and order economy. 
Arbitration

TRANSFER PRICING  The Vodafone Chronicles - Another Chapter begins Low value-adding intra-group services - OECD guidelines to add value to tax authorities arguments? TPO v. AO - Fight for right to decide business necessity?  Base Erosion &Profit; Shifting. BEPS Action plan 8 on special considerations for intangibles. Fee for Technical Services. MFN and 'Make Available' pairs up-Taxpayer gains. ROYALTY. Withholding on royalty payments-where it is heading? PERMANENT ESTABLISHMENT. Contract assignments and PE constitutions. Evolution for PE code. OUTBOUND INVESTMENT. Interest deduction on foreign loans and advances. INTERNATIONAL TAXATION. 'Moral hazards' of tax legislations. Decoding FATCA - Implications and Ramifications for India. INCOME FROM SHIPPING. Let the Ship sails, tax free between Indian ports.

Fiscally transparent entities

• Eligibility for tax treaty  benefits

Tax Transparent Partnership firms

• Recognition for treaty  purposes

Expatriate Taxation

•Global  mobility: Taxation aspects and controversy

Also Covering                                         

•  Treaties  :  Tax Efficient  & Treaty  Shopping

•  BEPS Action  Plan 5

•  OECD Guidance  on Transfer  Pricing Aspects of Intangibles

•  Deferred  consideration   from  an Indian taxation  perspective

•  U.S. Citizens and Green Card holders  :   Investments  in non-U.S. investment funds

-Transfer Pricing – No TP Adjustment on issue of shares
-Adjustment of excess/shortfall in ALP – New perspective
-Syncronisation of Related Party Dealings
-Transfer Pricing Documentation

Most Comprehensive Database on International Taxation with Research Tools & Customized Search

-Indian & Foreign Case Laws on International Taxation 
-Indian & Foreign Statutes pertaining to International Taxation
-Tax Treaties  / Model Tax Treaties & Model Commentaries
-Articles & Legal Commentaries 
-Videos & PPTs on International Taxation Conference 
-Research Tools 
-Foreign Exchange Laws 
-Indian Tax Laws
-Taxmann's Search

Most Comprehensive Database on International Taxation with Research Tools & Customized Search -Indian & Foreign Case Laws on International Taxation -Indian & Foreign Statutes pertaining to International Taxation -Tax Treaties / Model Tax Treaties & Model Commentaries -Articles & Legal Commentaries -Videos & PPTs on International Taxation Conference -Research Tools -Foreign Exchange Laws -Indian Tax Laws -Taxmann's Search

- Transfer Pricing
- Outbound Investments
- GAAR
- Permanent Establishment
- Royalty
- Finance (No. 2) Act 2014
- BEPS and EU Tax Developments

November 2015

October 2015

September 2015

August 2015

July 2015

June 2015

May 2015

April 2015

March 2015

February 2015

January 2015

December 2014

November 2014

October 2014

September 2014

August 2014

1. You agree that the use of Magzter.com, the application and its services, are at solely at your own risk. Neither Magzter.com nor its associates nor employees nor third party content providers guarantee that the service will be completely uninterrupted or error-free or foolproof against miscreant activities. Nor do they warranty that you will get the exact results as expected or promised by the website or product.

11. THE SERVICE AND ALL PUBLICATIONS ARE PROVIDED ON AN 'AS IS' AND 'AS AVAILABLE' BASIS. MAGZTER, ITS AFFILIATES, SUPPLIERS, LICENSORS AND AGENTS EXPRESSLY DISCLAIM ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. WITHOUT LIMITING THE FOREGOING, NEITHER MAGZTER NOR ITS AFFILIATES, SUPPLIERS, LICENSORS OR AGENTS, MAKES ANY WARRANTY THAT (I) THE SERVICE WILL MEET YOUR REQUIREMENTS, (II) THE SERVICE WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE, (III) THE INFORMATION THAT MAY BE OBTAINED FROM THE USE OF THE SERVICE OR THAT MAY BE CONTAINED IN THE PUBLICATIONS WILL BE ACCURATE OR RELIABLE, OR (IV) THE QUALITY OF ANY PUBLICATIONS OR THE SERVICE WILL MEET YOUR EXPECTATIONS. YOU ARE SOLELY RESPONSIBLE FOR OBTAINING AND MAINTAINING RELIABLE INTERNET CONNECTIVITY AND YOUR DEVICE. MAGZTER IS NOT RESPONSIBLE FOR YOUR INABILITY TO DOWNLOAD CONTENT. ANY MATERIAL DOWNLOADED OR OTHERWISE OBTAINED THROUGH THE USE OF THE SERVICE IS DONE AT YOUR OWN DISCRETION AND RISK AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR MOBILE DEVICE OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OF ANY SUCH MATERIAL. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM MAGZTER OR THROUGH OR FROM THE SERVICE SHALL CREATE ANY WARRANTY.

2. You will maintain and promptly update that information to keep it true, accurate, current and complete. You are responsible for maintaining the confidentiality of your account and password and for restricting access to your computer, and you agree to accept responsibility for all activities that occur under your account, including the selection and use of all content and services.

2.You will maintain and promptly update that information to keep it true, accurate, current and complete. You are responsible for maintaining the confidentiality of your account and password and for restricting access to your computer, and you agree to accept responsibility for all activities that occur under your account, including the selection and use of all content and services.

3. In no event will Magzter.com or any person or entity or third party involved in the creation, production and distribution of the content on the website and the application be liable in contract or legally for any damages, including and not limited to, direct, indirect, incidental, special, and consequential incurred to you while or on using Magzter.com. By registering on the website or downloading the application, you agree that the provisions mentioned in this section shall apply to all use of and content on the website and the application.

3. Without prior written or authorised permission from Magzter, you should not modify, copy, distribute or sell any content obtained from Magzter as everything published here is the proprietary property of Magzter or its licensors. As such unauthorised use may also violate applicable laws including copyright and trademark laws, Magzter strictly prohibits these and will terminate your access and account if any such illegal activity is proved or detected. You should also stand liable for the damages caused by these unauthorised activities. Except as permitted by the Publication's lawful owner, you acknowledge that you do not acquire any ownership rights by downloading Publications accessed through the Service. Except as explicitly required under copyright law or permitted by the features of the Service you may not modify, reverse engineer, publish, transmit, display, participate in the transfer or sale, create derivative works of, or in any way commercially exploit or provide to a third party the content of the App, the Publications, or any portion of them without the express permission of Magzter and the owner of such content. We do not grant you any licenses, express or implied, to the intellectual property of Magzter or Magzter's licensors.

5. You specifically acknowledge that Magzter.com is not liable for any kind of defamatory or offensive or illegal conduct of other users or third parties or their content and that the risk of injury from the foregoing rests entirely with you.

8. Magzter reserves all rights to monitor the content published and inputted by you for the purpose of determining whether you are compliant with these terms and conditions and other operating rules determined by Magzter. Magzter has the right to take decisions about the content and delete them at its own will.

9. Magzter is a distributor and NOT a publisher of the Publications and so Magzter has no editorial control over the content, including opinions, advice, statements, services, offers etc., that is represented in the magazines. So Magzter will not take responsibility for the accuracy or the reliability for any information or facts provided therein or that is made available through the service, by anyone other than authorised Magzter employees who are acting on their official capacities. Accordingly, we have no editorial control over the Publications. Any opinions, advice, statements, services, offers or other information or content expressed or made available by third parties, including those made in Publications offered by the Service, are those of the respective author(s) or publisher(s) and not of Magzter. Magzter will not be liable for any loss or damage caused by your reliance on information obtained through the Service or from the Publications. The Service may contain links to other Internet sites and third-party resources and Magzter does not assume any responsibility or liability for communications or materials available at such linked sites. These links are provided for your convenience only. You are solely responsible for understanding any terms and conditions that may apply when you visit or place an order through a third-party site.

Details of the objectionable content, including its link on our platform

Download your favorite titles and read them offline, anytime and anywhere

Gift your loved ones with a Magzter Gift Card instantly and give them the freedom to read their favorite magazines and newspapers from thousands of best-selling titles.

Gift your loved ones with a Magzter Gift Card instantly and give them the freedom to read their favorite magazines from thousands of best-selling titles.

Gift your loved ones with a Magzter Gift Card instantly and give them the freedom to read their favorite magazines from {{magCount}} best-selling international titles.

Girish Ramdas is the Co-founder and CEO of Magzter, a New York based startup that has been making waves in the global digital publishing business. Magzter has crossed 80 million users since its inception in 2011 from more than 150+ countries with 1000s of magazines, newspapers and books from more than 4,500 publishers worldwide. He has more than 25 years of experience in cross-platform publishing, including print, mobile, and Web development. During this period, he has co-founded and run three successful start-up businesses. He has enabled magazine companies to go digital and helps them monetize their content across the digital world. Girish's deep industry experience in online, mobile and publishing ecosystems has made him an expert in acquisition, marketing and monetizing digital content across platforms globally.

In the event that you encounter any objectionable content on our platform, we have put in place a grievance redressal policy to address your concerns.

Magzter Inc. (“Company”, “we”, “us” or “our”) knows that you care about how your personal information is used and shared. Please read the following privacy policy (the “Policy”) to learn more about our privacy practices. By visiting any of the websites operated by the Company, and any sub-domains thereof, or using any of our mobile applications and other methods of content distribution (collectively, the “Service”), you acknowledge that you accept the practices and policies outlined in this Policy, and you hereby consent that we will collect, use, and share your information in the following ways.

Magzter Inc. is the World's largest and fastest growing self-service, cross-platform digital newsstand with over 80 million users since its inception in 2011 and thousands of magazines and newspapers across 40+ categories and 60+ languages. Headquartered in New York, Magzter has its local presence in Amsterdam, London, Mexico City, Chennai, Mumbai, New Delhi, Bengaluru, Singapore, and will soon be expanding to other countries. Founded by global entrepreneurs, Girish Ramdas and Vijay Radhakrishnan in June 2011, Magzter enables magazine and newspaper publishers around the world to create and deliver digital editions of their titles to global consumers.

Magzter is committed to providing a safe and secure platform for our users. Please note that Magzter is merely a platform for publishers to distribute their content. We do not control or endorse the content published on our platform. We cannot be held responsible for the actions of our publishers or their content.

Magzter is not responsible for compensating any party that has suffered damages or incurred costs due to any content, or part of the content, that violates their rights. Magzter is not liable to face any legal action in civil court for any violation of rights caused by any content, or part of the content, that infringes the rights of a third party.

Magzter offers the world’s largest {{allyoucanread}} subscription service called {{gold}} which gives digital readers unlimited access to 8,500+ magazines and newspapers for a monthly subscription price. Magzter also has the largest number of stories in the world with its game-changing ezRead 2.0 feature for its apps, which enables smartphone and small-screen mobile users to enjoy magazine content the way it was meant to be enjoyed, with article text that is easy to read and is accompanied by stunning videos and high resolution photography.

Magzter offers the world’s largest “All-You-Can-Read” subscription service called Magzter GOLD which gives digital readers unlimited access to 8,500+ magazines and newspapers for a monthly subscription price. Magzter also has the largest number of stories in the world with its game-changing ezRead 2.0 feature for its apps, which enables smartphone and small-screen mobile users to enjoy magazine content the way it was meant to be enjoyed, with article text that is easy to read and is accompanied by stunning videos and high resolution photography.

Name

Note: This will only share the cover and the publication information, but not the content.

Please fill out this form if you need any help regarding publishing your content on Magzter

Prior to Magzter, he was the President of Dot Com Infoway (DCI) and Galatta Media. His duties included strategic marketing, partnership development, and monetizing content globally. DCI grew from a small team of 3 in 2000 to 300 by 2011 and was dealing with web, software and app development for clients globally.

Since we launched, Magzter has been committed to partnering with global organizations to provide the greatest possible newsstand technology & service to our customers. Whether you are looking to offer magazine subscriptions to your customer database or just want to learn more, Magzter is committed to helping your business grow. To find out more, please fill out the questionnaire below:

The DMCA allows us to restore the removed content if the party filing the original DMCA Notice does not file a court action against you within ten business days of receiving the copy of your Counter Notice.

This Policy covers Company’s treatment of personally identifiable information (“Personal Information”) and other information about you and your computer or device that Company gathers when you are accessing the Service. We may collect Personal Information from you, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including to personalize, provide, and improve our products, services, content, and advertising, and to allow you to set up a user account and profile, to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described in point 4.

This title is included with your Magzter GOLD subscription

To analyze the quality of content and provide appropriate feedback to publishers

We have designated a Grievance Officer to address any complaints related to objectionable content.

We request that any complaint related to objectionable content be sent to the Grievance Officer through email to the above-mentioned email address. We also request that you provide the following details when making a complaint:

and the App that provides you the capability to order, subscribe to and receive the delivery of various magazines, books, news and magazine and publication related content (collectively known as 'Publications') and to have these digital versions of the Publications delivered to you

c. We also collect information associated with your use of the application in order to make personalized recommendations. If you provide your third-party account credentials to us, you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us if you authorize such transmissions, and that Third Party Account Information transmitted to the Service is covered by this Policy.

f. The Personal Information we collect allows us to respond to your requests, improve our products and services, customize the advertising and content you see, and communicate with you about new products.

is the World's largest and fastest growing self-service, cross-platform digital newsstand with over 87 million users since its inception in 2011 and thousands of magazines and newspapers across 40+ categories and 60+ languages. Headquartered in New York, Magzter has its local presence in Amsterdam, London, Mexico City, Chennai, Mumbai, New Delhi, Bengaluru, Singapore, and will soon be expanding to other countries. Founded by global entrepreneurs, Girish Ramdas and Vijay Radhakrishnan in June 2011, Magzter enables magazine and newspaper publishers around the world to create and deliver digital editions of their titles to global consumers.

n. We will also use usage information in order to ensure users adhere to our Terms of Use. For example, a user’s usage information will help us confirm that a user only downloads a magazine or other content a permitted number of times or to a permitted number of devices.

which gives digital readers unlimited access to 8,500+ magazines and newspapers for a monthly subscription price. Magzter also has the largest number of stories in the world with its game-changing ezRead 2.0 feature for its apps, which enables smartphone and small-screen mobile users to enjoy magazine content the way it was meant to be enjoyed, with article text that is easy to read and is accompanied by stunning videos and high resolution photography.

{{magzter}} is the World's largest and fastest growing self-service, cross-platform digital newsstand with over 87 million users since its inception in 2011 and thousands of magazines and newspapers across 40+ categories and 60+ languages. Headquartered in New York, Magzter has its local presence in Amsterdam, London, Mexico City, Chennai, Mumbai, New Delhi, Bengaluru, Singapore, and will soon be expanding to other countries. Founded by global entrepreneurs, Girish Ramdas and Vijay Radhakrishnan in June 2011, Magzter enables magazine and newspaper publishers around the world to create and deliver digital editions of their titles to global consumers.

International Taxation Magazine - October 2015

International Taxation Magazine - October 2015

In this issue

International Taxation Magazine Description: