SKP
Articles
India’s 2017 budget: TP highlights and lowlights
2 February 2017, TP Week

India’s Budget, announced on 1 February, took another step towards implementing the OECD’s policy recommendations. Highlights include introducing secondary adjustments, restricting interest rules, and curtailing the scope of domestic transfer pricing provisions. But what does all this mean for taxpayers? Perhaps the largest, and least welcome, change came in the form of secondary adjustments.

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Curb on debt funding - Limiting the deduction of interest paid
2 February 2017, Taxsutra

OECD BEPS Action Plan 4 dealt with “Limiting Base Erosion Involving Interest Deductions and Other Financial Payments”. The primary objective of OECD BEPS Action Plan 4, was to design rules to prevent base erosion/profit extraction by the multinationals through the use of abusive financing structures which could be through higher levels of debt in high tax countries, intra-group loans to generate interest deductions in excess of the group’s actual third party interest expense and third party or intra-group financing to fund the generation of tax exempt income...

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Maulik Doshi explains the concept of secondary adjustment introduced in Budget 2017
1 February 2017, Bloomberg Quint

Maulik Doshi, Partner - International Tax and Transfer Pricing, explains that a secondary adjustment implies that the taxpayer would not only have to pay taxes on the primary additions to taxable income but also have to record the same in the books of accounts.

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Maulik Doshi discusses Union Budget 2017
1 February 2017, Taxsutra

Maulik Doshi, Partner - International Tax and Transfer Pricing, gives his insights on Union Budget 2017 and covers the key features of the Budget. To know more, read his complete quote on Taxsutra's website.

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SKP Direct Tax Wish List

The Union Budget 2017 session will commence a month earlier on 31 January 2017 and the industry as a whole is expecting some major economic reforms to be introduced. Some of the direct tax reforms that are expected include changes in tax rates, tax incentives, TDS related measures and movement towards a stable tax regime. One can also expect changes to ease doing business in India.

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SKP Indirect Tax Wish List

Over the past two years, the implementation of GST has been a top priority of the government. Subsequently, the government introduced the 122nd Constitution Amendment Bill (CAB) to enable the implementation of GST in India, which received Presidential assent in September 2016. The Union Budget 2017 is expect to bring in changes that will align indirect taxes to the much awaited GST regime.

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Budget 2017: GAAR Is Not Too Far... Anymore
27 January 2017, Bloomberg Quint

Every time GAAR has been due for implementation in India, the clamour to delay the tax change has risen too. But the Narendra Modi government remains steadfast in its decision to implement General Anti Avoidance Rule (GAAR).

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Budget 2017: What The Government Should Do To Entice Foreign Portfolio Investors?
26 January 2017, Bloomberg Quint

The Indian debt market has seen a significant interest and participation from FPIs in the past couple of years. In financial year 2014-15, FPIs invested Rs 1,661.27 billion (approx. $24.43 billion as per the current exchange rate) in debt securities; almost 50 percent higher than FPI inflows into equities.

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India’s renegotiated DTAs creating investment diversions
25 January 2017, International Tax Review

India’s recent renegotiations of its agreements on the avoidance of double taxation (DTAs) has made fundamental changes to how favoured gateways are used for investing in India. Amelia Schwanke explores the catalysts that initiated the renegotiations and the new treaty structures that have replaced outdated policies.

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Tax Department Issues ‘Place Of Effective Management’ Rules To Stop Evasion By Foreign Companies
24 January 2017, Bloomberg Quint

To determine the residential status of foreign companies, the Finance Act 2015 introduced the concept of place of effective management or POEM. If a company’s place of effective management is India, it will be treated as an Indian resident and its global income will be taxable in India.

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Angel Investment Tax Has Startups And Their Investors Worried
17 January 2017, Bloomberg Quint

In February last year, the government kicked off its Startup India initiative ‘for creating a conducive environment for startups in India.’ But a flurry of recent tax notices to startups and their investors tell a different story.

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