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We are pleased to attach herewith the Tax & Regulatory Newsletter for June 01- June 30, 2018, highlighting major recent tax and regulatory developments.

 

Inside this issue…

 

DIRECT TAX                                                                                                                                                      

  1. AAR: US-parent Co’s income from authorised Indian reseller for content delivery solutions not taxable
  2. Mumbai Tribunal holds capital gains earned by Singapore Company from trading in Indian securities as non-taxable in India
  3. Ahmedabad ITAT: Mere TRC non-furnishing cannot disentitle treaty benefits; Explains Section 90(4) interplay vis-à-vis treaty override u/s. 90(2); at the same time Taxpayer must submit supporting documents to substantiate tax residency in country, whose tax treaty benefits are sought
  4. Delhi ITAT special bench holds that Nokia’s subsidiary doesn’t constitute the PE of Nokia Networks

 

INTERNATIONAL TAX

  1. Time to ‘definitively address’ Ireland’s tax haven reputation
  2. Dividends Soar to Record After Tax Cuts and Bank Stress Tests
  3. German tax law permitting loss carry forward following restructuring of failing companies is not State aid, EU court rules
  4. UK tax treaty anti tax avoidance changes to apply from 2019
  5. OECD Welcomes Dutch Efforts To Counter BEPS

 

TRANSFER PRICING

  1. ITAT deletes adjustment on Advertisement, Marketing and promotional expenses in the absence of any prior agreement or arrangement with the AE
  2. ITAT Deletes TP-adjustment on interest-free advances for equity investment
  3. ITAT: Rejects bank quotes average as guarantee ALP; Averages don’t always give logical results
  4. ITAT held that attribution of profits to Indian Branch should be based on FAR Analysis

 

We trust that you will find it interesting and informative.
Nangia Advisors LLP – Tax and Regulatory Newsletter – June 01 – June 30, 2018