The Government levied additional duties on exports of petroleum crude, petrol, diesel and aviation turbine fuel to tax the windfall gains earned by petroleum companies on exports. The situation shall be reviewed weekly, and the additional levies would be withdrawn only if the global oil prices fall by USD 40/barrel. The Press Release dated July 01, 2022 detailing the Government’s motives behind these levies can be accessed here.
Last month USISPF, along with our knowledge partner Deloitte India conducted an interactive session to discuss the recent trends in APA and MAP in India and the US. The session provided insights on the evolution of APA and MAP program, its progress to date and way forward, both in India and the US. A summary of key discussion points which are accessible here. As next steps, we look forward to receiving feedback from our members on the following:
1. Regulatory issues and resultant challenges in APA and MAP if any
2. Your view on the outcomes under APA and MAP and how it has helped in financial planning of the group.
3. Suggestions if any on the safe harbour rules / rates with rationale and experience so far
4. Any other suggestion as appropriate
We intend to submit a detailed note to the concerned department at Ministry of Finance by the end of this month hence please share your suggestions if any by June 5th .
To bring parity in the tax treatments for the Organisation for Economic Cooperation ad Development (OECD) member nations, the concept of Most Favoured Nation (MFN) is prevalent under International tax laws. Central Board of Direct Taxes has issued clarifications around the applicability of MFN clause of Indian Double Taxation Avoidance Agreements (DTAAs or treaties) with OECD member states (or countries). Please access the CBDT circular here.
OECD has released Draft Rules for Nexus & Revenue Sourcing as a part of multi-stage public consultation for Amount A of Pillar One. Click here to read the OECD Press Release and also to download the public consultation document.
The OECD has published detailed rules to assist in the implementation of a landmark reform to the international tax system, which will ensure Multinational Enterprises (MNEs) will be subject to a minimum 15% tax rate from 2023. The Pillar Two model rules provide governments a precise template for taking forward the two-pillar solution to address the tax challenges arising from digitalisation and globalisation of the economy agreed in October 2021 by 137 countries and jurisdictions under the OECD/G20 Inclusive Framework on BEPS. Please refer to the rules along with the press release here.
CBDT, vide Circular No. 20 of 2021 has issued much awaited guidelines on scope of Sections 194-O(4), 194Q(3) and 206C(1-I). Click here to read and download the CBDT Circular.
OECD/G20 Inclusive Framework on BEPS releases fifth annual Peer Review Report assessing 131 jurisdictions’ progress on exchanging information on tax rulings, in accordance with Action 5, for the calendar year 2020. This is the first review taking place under the renewed peer review process, agreed upon by the member nations last year, with a view to further enhancing and consolidating transparency in relation to the issuance of tax rulings; Click here to read and download the Annual Peer Review Report.