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

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

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

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

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

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August 2014

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International Taxation Magazine - February 2015

International Taxation Magazine - February 2015

In this issue

International Taxation Magazine Description: