Mumbai bench of the Income-Tax Appellate Tribunal in favour of the US multinational sets a precedent for the taxation of the franchise model good news for franchises of foreign brands that already operate across India. Foreign multinationals can expand their brand presence in India through a franchise agreement without suffering a higher tax burden imposed on permanent establishments (PE) following the Domino’s Pizza case Suraj Nangia, Partner shares his views on…
Read MoreImpact of US BEAT on the Indian IT sector
The Indian Information technology (IT) and business process management (BPM) industry as we all knew till date was highly dependent on U.S. corporations offshoring the work to be conducted from India. This was primarily owing to the fact that India offers a 25-30 per cent cost savings to the U.S. Corporations offshoring the work to them. The cost saving offered by Indian IT-BPM industry is not only attributable to the…
Read MoreIndian tax landscape changing for better
India is moving at a rapid pace on the path of economic growth and Indian tax landscape has witnessed multifarious changes in the recent past. Indian Government has been steadily working toward widening the tax base, addressing the menace of the parallel economy, improving the ease of doing business and strengthening the anti-abuse provisions. Past year was marked by some major reforms for multinationals viz. “One nation One Tax” –…
Read MoreSuraj Nangia, Partner features in Virtual Round Table Series Tax Working Group 2018 conducted by IR Global – UK
This Virtual Series provides an update on CRS implementation from a range of jurisdictions in which IR Global tax experts are currently operating. This discussion involves IR Global members from India, Spain, Luxembourg, New Zealand and Lebanon. The discussion touches on whether CRS has caused any conflict or tension during implementation, given issues such as the LuxLeaks Scandal and Lebanon’s entrenched banking secrecy and also whether CRS has affected advice…
Read MoreMobilisation/Demobilisation Charges Form Part of ‘Receipts’ Under Section 44BB – Suraj Nangia
Suraj Nangia, Partner with inputs from Mansi Chopra, Manager – Direct Taxation contributed an article on Mobilisation/Demobilisation charges from part of “receipts” under section 44BB for Corporate Professionals Today (Taxmann).
Read MoreIndia Top Court: Auxiliary Functions Don’t Decide Tax Residency- Suraj Nangia
India’s top court passed a highly significant judgment on the taxability of outsourcing arrangements between Indian affiliates and their global counterparts by validating that a subsidiary performing backend operations in India doesn’t constitute a permanent establishment. Suraj Nangia, Partner shares his views on aformentioned story for Bloomberg-BNA.
Read MoreService Permanent Establishment-Changing Landscape – Suraj Nangia
Recently, the Tribunal, had made interesting observation in case of ABB-FZ [2017] 83 Taxmann 86 (Bengaluru – Trib) while interpreting provisions of service PE. It held that for constituting a Service PE it is not the stay of employees for the specified period which is required to be met but continuous rendition of services by the foreign company. Suraj Nangia, Partner with inputs from Mansi Chopra, Manager, Nangia & Co LLP contributed…
Read MoreF1 Circuit—A Fixed Place PE! – Suraj Nangia
Concept of Permanent establishment (‘PE’) is an important subject for any company operating or planning to operate in another country, in order to determine whether the company’s activities in a country are taxable in that country. Determining whether a company has triggered a PE is seldom clear cut, since it is highly facts driven. Suraj Nangia, Partner with inputs from Mansi Chopra, Manager contributed an article on formula one ruling…
Read MorePayment for Usage of Marks/Logos – Whether Royalty?- Suraj Nangia
How crucial marks/logos/designs (collectively hereinafter referred to as “marks”) are for an enterprise is a well acknowledged fact. In the current dynamic business scenario an entity’s identity and existence are dependent on how well it is able to establish itself in the minds of the people. To achieve this objective, organisations constantly undertake extensive advertisements and promotional activities. With businesses being carried on across the borders, multinationals join hands to…
Read MoreWho could have thought a car race track could be a PE in India !!
Concept of Permanent establishment (‘PE’) is an important subject for any company operating or planning to operate in another country, in order to determine whether the company’s activities in a country are taxable in that country. Determining whether a company has triggered a PE is seldom clear cut, since it is highly facts driven. The laws and enforcement practices of the target or host country, applicable tax treaties and the…
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