As an active participant in the OECD’s base erosion and profit shifting (BEPS) project, India has implemented nearly all the BEPS recommendations and has taken several steps to amend the country’s domestic tax laws appropriately. The Indian Finance Act, 2016 implemented BEPS Action Item 13 by introducing a three-tiered transfer pricing documentation structure and made it effective from the 2016-17 financial year.
The Indian tax authority has published for public comments a draft Notification, which will implement the OECD’s proposals under Action 5 of the base erosion and profit shifting (BEPS) project.
India’s Union Cabinet has approved revision of the country’s tax treaty with Qatar.
The revised tax treaty includes a limitation of benefits clause to prevent treaty shopping. It meets the base erosion and profit shifting (BEPS) minimum standards on treaty abuse (BEPS Action 6) and mutual agreement procedure (BEPS Action 14).
The Indian Government has approved the country’s tax treaty with Iran.
The tax treaty is in line with the ones entered into by India with other countries. The proposed treaty also meets tax treaty-related minimum standards proposed under the OECD’s base erosion and profit shifting project, in which India is participating on an equal footing.
On March 5, 2018, the Hong Kong Government launched an online portal to enable Hong Kong entities to file their country-by-country (CbC) reports. The Portal can be accessed through: https://aeoi.ird.gov.
An amending Protocol to the UK-Mauritius tax treaty was signed on February 28, 2018.
Singapore and Tunisia have signed a tax treaty, which provides for low withholding tax rates and a detailed exchange of information provision.
India’s Central Board of Direct Taxes (CBDT) entered into a further seven unilateral advance pricing agreements (APAs) in February 2018, taking the total number of APAs signed to 203.
Chartered Accountants Australia and New Zealand (CA-ANZ) has stressed that by implementing the Taxation (Neutralising Base Erosion and Profit Shifting) Bill in its current form, the New Zealand Government would be “going further than most other OECD countries.”
By Alex Cooper
On February 23, 2018, the Inland Revenue Authority of Singapore (IRAS) published key updates and amendments to the country’s transfer pricing guidelines, including new transfer pricing documentation requirements.