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Monthly Archives: June 2012
Transfer pricing – ravages of retrospective legislation
With the parliamentary introduction of the Tax Laws Amendment (Cross-Border Transfer Pricing) Bill (No. 1) 2012 firing up sentiments on all fronts, especially in respect of the Bill’s retrospectivity, a similar resentment is brewing in India. Following the decision in Vodafone the Government announced tightening the anti-avoidance and transfer pricing rules. Reports are coming in that it has been decided to defer the introduction GAAR by an year after FII (foreign institutional investment) holdings pulled out nearly $ 1 … Continue reading
Transfer pricing – OECD Model Tax Convention, commentaries and guidelines
The Tax Laws Amendment (Cross-Border Transfer Pricing) Bill (No. 1) 2012 now before Parliament seeks to introduce the use of OECD Model tax Convention and its commentaries and the transfer pricing guidelines, in the interpretation of international tax agreements as at 22 July 2010 , to the extent they are relevant. This inevitably poses the question whether it is prudent buy viagra online to limit the use of the commentaries and guidelines made up to 22 July 2010. and ignore … Continue reading
