How Is The International Tax And Transfer Pricing Landscape Evolving In India?

Webinars | Asia

International tax and Transfer Pricing landscape has witnessed reformatory transformation in recent years, especially after the launch of Base Erosion and Profit Shifting (BEPS) Action Steps in 2013 and subsequent issuance of the final measures in October 2015.

India has an observer status with OECD, represents G20 countries and is an active participant in OECD’s initiatives. India has applied several BEPS recommendations in last few years, namely signing of Multilateral Instruments, introduction of Country by Country Reporting (CbCR), Master file, secondary adjustments, GAAR, thin capitalisation rules, reinforcing substance requirement in the tax statute with inclusion of Significant Economic Presence there. Several landmark judgements have also been pronounced on key international tax issues.

The MNEs operating in India therefore need to examine and align their tax positions and Transfer Pricing documentation and Policies with these changes. It becomes essential for the tax and finance department in the MNE to gain an understanding of the plausible impact, issues and solutions surrounding the transformed international tax and transfer pricing landscape, in order to plan their risk mitigation strategies appropriately.

Key Highlights of the webinar

This Webinar analyses the following:

  • Does Action 13 change the attractiveness of unilateral APAs in India?
  • Are the issues surrounding Marketing intangibles, characterisation of Captive R&D Centres and secondary adjustments resolved?
  • What is the BEPS Impact of Business Connection expanded through ‘Significant Economic Presence’?
  • Discussion on the landmark judgements on Permanent Establishment, such as Formula One and E-Funds, and the views on Profit Attribution in India – Global Formulary Approach vs. FAR Analysis?
  • India’s MLI Position - Interplay of GAAR and PPT for countering treaty abuse
  • Indirect transfers law – Pending unaddressed issues post issuance of Final Valuation Rules

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