International Taxation - January 2015

In this issue

TRANSFER PRICING The Vodafone Chronicles - Another Chapter begins Low value-adding intra-group services - OECD guidelines to add value to tax authorities arguments? TPO v. AO - Fight for right to decide business necessity? Base Erosion &Profit; Shifting. BEPS Action plan 8 on special considerations for intangibles. Fee for Technical Services. MFN and 'Make Available' pairs up-Taxpayer gains. ROYALTY. Withholding on royalty payments-where it is heading? PERMANENT ESTABLISHMENT. Contract assignments and PE constitutions. Evolution for PE code. OUTBOUND INVESTMENT. Interest deduction on foreign loans and advances. INTERNATIONAL TAXATION. 'Moral hazards' of tax legislations. Decoding FATCA - Implications and Ramifications for India. INCOME FROM SHIPPING. Let the Ship sails, tax free between Indian ports.

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