The application of arm’s length principle (ALP) to intra-group Financial Transactions (FT) has been an intricate and contentious issue for multinational enterprises (MNE) in recent years. Recently, two of the big intergovernmental organizations, Organisation for Economic Cooperation and Development (OECD) and the United Nations (UN) released a series of proposals (in July 2018 by OECD and on 08 April 2019 by UN) with respect to FT. Nitin Narang, Partner and Adarsh Rathi, Director- Transfer Pricing & International Tax contributed an piece on UN Draft Guidance on Financial Transactions – A Welcome Move for Tax sutra

Aimed at providing relief to subsidiaries of US multinationals and ensuring a check on cross-border tax evasion, India has notified the inter-governmental agreement with the United States for exchange of country-by-country (CbC) reports filed by multinational enterprises (MNEs) regarding income allocation and payment of taxes. india-notifies-pact-with-us-to-check-tax-evasion-by-mncs-nitin-narang-2

Aimed at providing relief to subsidiaries of US multinationals and ensuring a check on cross-border tax evasion, India has notified the inter-governmental agreement with the United States for exchange of country-by-country (CbC) reports filed by multinational enterprises (MNEs) regarding income allocation and payment of taxes. Nitin Narang, Partner- Transfer Pricing shares his views on aforementioned story for PTI- Standalone story. (This news has been picked up by 310 other news publications including Economic Times, Business Standard, Indian Express, Business Today etc.) india-notifies-pact-with-us-to-check-tax-evasion-by-mncs-nitin-narang

Indian arms of US MNCs will not have to file country by country or CbC report here. India has finalized bilateral competent authority arrangement for exchange of CbC reports with US. These companies would have had to file these here with Indian revenue authorities by March 31, 2019 in absence of such an agreement. Nitin Narang, Partner- Transfer Pricing shares his views on aforementioned story for following publications: Economic Times- Standalone story Financial Express- Standalone story