Greetings!

We are pleased to attach herewith the Tax & Regulatory Newsletter – April, 2019 Edition highlighting major recent tax and regulatory developments.

Inside this issue…

DIRECT TAX

Grouting not ‘construction’, taxpayer constitutes Fixed Place PE
Management services taxable as business profit in absence of FTS clause
Delhi ITAT holds that CIT(A) can’t impose Rule 11UA when taxpayer ‘substantiated’ higher valuation u/s. 56(2)(viib) before assessing Officer

INTERNATIONAL TAX

Governments use receipt lotteries to boost tax compliance
Ukraine ratifies MLI to amend tax treaties
Switzerland Introduces New Tax Rule for Systemically Important Banks France tries to set trend with internet tax bill
Australia embraces international co-operation to solve tax challenges posed by the digitalized economy
Georgia ratifies tax instrument to tackle BEPS
Taiwan Plans Extension of Tax Incentives for R&D Expenses

TRANSFER PRICING

Application of Transfer Pricing provisions not against “non-discrimination” clause of DTAA; DCF valuation subsumes goodwill
HC Accepts “headcount method” as a basis for apportionment of un-allocable cost
Company cannot be rejected as a comparable merely on following different-FY wherein the data can be collated from the public domain relating to the year under consideration

REGULATORY

Recent amendment in Companies (Incorporation) Rules
Issue of Master Direction on External Commercial Borrowings and Trade Credits by RBI
Tax & Regulatory Newsletter - April, 2019 Edition
Nangia & Co LLP_Newsletter_ April , 2019 Edition