TIGER GLOBAL AAR RULING: ISSUES FOR RE-CONSIDERATION
India-Mauritius tax treaty has come under scanner yet again with a recent pronouncement by the Authority for Advance Rulings (“AAR”) in the case of Tiger Global International II Holdings, In re[1]. The AAR was called upon to adjudicate whether capital gains arising from the sale of shares held by Mauritius based Applicant companies [with further …
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Accept – Reject of Comparables- When can it constitute a ‘substantial question of law’?
Accept – Reject of Comparables- When can it constitute a ‘substantial question of law’? Comparability analysis is one of the most critical aspects of Transfer Pricing benchmarking and therefore it comes as no surprise that selection of comparables has been one of the highly litigated issues before Indian Courts.
Extending the Reach of Indian Safe Harbour Provisions and Advance Pricing Agreement (Transfer Pricing) – A Critical Analysis
Few months back, Indian Government in the February 2020 Budget stipulated a number of significant proposals on Transfer Pricing Regime in relation to Safe Harbour Rules and APAs. In this article, we examine the changes to Indian Safe Harbour and APA rules critically evaluating the benefit and implications of these changes for multinational companies insofar …