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Corporate Taxes

G20 New Delhi Leaders Declaration: The G20 New Delhi declaration reaffirms commitment toward swift implementation of the two-pillar international tax package and continued cooperation towards a globally fair, sustainable and modern international tax system

OECD Secretary-General releases Tax Report to G20 leaders outlining the current status and progress on the Two-Pillar international tax reform package

August 2023

CBDT issues guidelines and notifies Rule 11UACA to clarify the taxation of income received from life insurance policy

Applicability of Safe Harbour Rules extended to Assessment Year 2023-24
CBDT releases Handbook on Board for Advance Rulings
CBDT notifies selection procedure and appointment terms for Dispute Resolution Committee
CBDT notifies 18 Dispute Resolution Committees across country
OECD invites public input on Amount B under Pillar One relating to the simplification of transfer pricing rules

July 2023

CBDT excludes fund relocation to IFSC from ambit of Sec.56(2)(x) of Income Tax Act

3rd G20 Finance Ministers and Central Bank Governors Meeting held on July 17-18. A High-Level Tax Symposium on Combatting Tax Evasion, Corruption and Money Laundering was also organised on the sidelines of this meeting. For more information click here.
OECD Secretary-General releases Tax Report to G20 Finance Ministers and Central Bank Governors. For more information click here.
15th Plenary Meeting of the OECD/G20 Inclusive Framework on BEPS was held on 11 July 2023, and approved the release of Outcome Statement on the Two-Pillar Solution. For more information click here.

May 2023

• Draft valuation rules released for public consultation, industry inputs invited

• Specified class of investors and start-up companies exempt from angel tax provisions notified
International credit card transactions over INR 700,000 to be brought under the ambit of Liberalised Remittance Scheme and subject to Tax Collection at Source of 20

February 2023

CBDT extends exemption from mandatory e-filing of Form 10F for non-residents up to September 30, 2023

The framework for the scheme can be accessed here.
The updated FAQs pertaining to the e-verification scheme can be accessed here.
The technical guidance titled ‘Agreed Administrative Guidance for the Pillar Two GloBE Rules’ can be accessed here.

December 2022

OECD released the latest mutual agreement procedure (MAP) statistics covering 127 jurisdictions. These statistics form part of the BEPS Action 14 Minimum Standard and the wider G20/OECD tax certainty agenda to improve the effectiveness and timeliness of tax-related dispute resolution mechanisms. Further details can be accessed here.
The Revenue Statistics 2022 report can be accessed here while the Consumption Tax Trends 2022 report can be accessed here.

November 2022

22 jurisdictions signed the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of information under the OECD Model Rules for Reporting by Digital Platforms, at the OECD Global Forum’s 15th Plenary Meeting.
OECD has published the compilation of public comments received on ‘Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One’. The report can be accessed here.

CBDT has released a draft format for a consolidated tax return, which also seeks information from Indians residing abroad on any business connections in India, and details of significant economic presence of such businesses, if any. This could have an impact on Indian traders on crypto exchanges even if not incorporated in India. The draft can be accessed here.

The due date for filing TDS Statement in Form 26Q for second quarter of FY 2022-23 has been extended by a month to Nov 30, 2022. The Circular No.21/2022 dated October 27, 2022 can be accessed here.
CBDT has released Explanatory Notes to Provisions of Finance Act, 2022 vide Circular 23/2022 dated November 03, 2022, which can be accessed here.
ICAI releases its Ninth Edition of the Guidance Note on Report under Section 92E which also incorporates amendments made by the Finance Act, 2022. The report can be accessed here.
The UN Sub-committee on Tax Matters has proposed to include a general “subject to tax” rule (STTR) in the United Nations Model Double Taxation Convention. The proposal can be accessed here.

October 2022

The OECD during the 14th plenary meeting of the G20 Inclusive Framework on BEPS released a Progress Report on the Administration and Tax Certainty Aspects of Amount A of Pillar One, and is now inviting public comments on the same. The report can be accessed here.

The OECD has released a new global tax transparency framework (named the ‘Crypto-Asset Reporting Framework’) for the reporting and exchange of information between countries on crypto-assets. The report can be accessed here.

The jurisdiction of CIT(A) for International Tax & Transfer Pricing cases across the country has been notified by CBDT. The applicable Notification No. 113/2022 dated October 13, 2022, can be accessed here.
The relevant Notification No. 112/2022 dated October 7, 2022 can be accessed here.

The Income Tax Department has published FAQs on filing of Form 27C. The FAQs can be accessed here.

September 2022

The World Bank has released a report titled ‘The Global Minimum Tax: from agreement to implementation’ analysing key elements of the Global Minimum Tax and its practical implementation in respective countries. The report can be accessed here.
The due date for filing tax audit report has been extended till October 07, 2022. The Circular No. 19/2022 dated September 30, 2022 can be accessed here.
CBDT notifies Rule 132 of the Income Tax Rules (with effect from October 01, 2022) prescribing rule and forms for taxpayers to make voluntary application with the tax authority for re-computation of total income to avoid deeming penal consequences for under-reported income on account of disallowance, on retrospective basis, of surcharge or cess as business deduction which was claimed and allowed in the past.
Deadline for filing Form ITR-A in the case of companies going through business re-organisation from April 01, 2022, to September 30, 2022 has been extended till March 31, 2023. The order dated September 26, 2022 can be accessed here.

The Central Board of Direct Taxes has issued further guidelines to address challenges in implementation of TDS under Section 194R of the Income Tax Act. The revised guidelines clarify many of the issues that the Tax Forum had advocated for on behalf of members.

CBDT issued Guidelines for Compounding of Offences under the Income-tax Act, which are set to supersede the earlier guidelines. The guidelines dated September 16, 2022 can be accessed here.

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