Latest Expert Exchange Queries
sitemapHome | Registration | Job Portal for CA's | Expert Exchange | Currency Converter | Post Matrimonial Ads | Post Property Ads
News shortcuts: From the Courts | News Headlines | VAT (Value Added Tax) | Service Tax | Sales Tax | Placements & Empanelment | Various Acts & Rules | Latest Circulars | New Forms | Forex | Auditing | Direct Tax | Customs and Excise | ICAI | Corporate Law | Markets | Students | General | Indirect Tax | Mergers and Acquisitions | Continuing Prof. Edu. | Budget Extravaganza | Transfer Pricing
Popular Search: TDS :: ARTICLES ON INPUT TAX CREDIT IN VAT :: empanelment :: VAT Audit :: form 3cd :: ICAI offer Get Windows 7,Office 2010 in Rs.799 Taxes :: due date for vat payment :: VAT RATES :: articles on VAT and GST in India :: list of goods taxed at 4% :: Central Excise rule to resale the machines to a new company :: ACCOUNTING STANDARD :: cpt :: TAX RATES - GOODS TAXABLE @ 4% :: ACCOUNTING STANDARDS
« News Headlines »
 Here's how to calculate tax payable on your capital gains
 Income Tax calculations for the financial year 2016-17
 CPE Events 17 October - 22 October 2016
 High Court raps I-T Department for wrong tax demand
  CBDT signs 5 advance pricing pacts with Indian taxpayers
 Finance ministry warns tax officials of action against GST protest
 Big changes for small units under GST
 Parliament’s winter session to begin on November 16 to expedite GST rollout
 Income-tax (27th Amendment) Rules, 2016 - 92/2016
 Announcement - Clarifications in Respect of MEF 2016-17
 Non-taxing GST apps to make filing income tax return less painful

I-T may ask Morgan Stanley arm to file return
July, 20th 2007
The Income-Tax (I-T) department proposes to ask US-based Morgan Stanley and Company to file its income-tax returns in India following the recent Supreme Court judgement.
The apex court has upheld the treatment of its business process outsourcing hub, Morgan Stanley Advantage Services (MSAS), as a service permanent establishment (PE).
According to an I-T department source, tax authorities may issue a notice if the returns are not filed within a weeks time after the formal communication is sent to the company. The returns will be useful in analysing the tax implications from the transfer pricing angle.
The source added that treatment of a BPO outfit as a service PE gives rise to various risks, if the contract fails.
Further, the department would also like to see whether the arms length treatment has been maintained on payments to employees on deputation from the overseas office.
The department is of the view that transfer pricing issues arising out of treatment of BPOs as service PEs have implications for other BPOs owned by foreign companies and such cases may also be opened for further scrutiny.
Allaying doubts over taxation of BPOs floated by foreign entities, the Supreme Court, in its landmark judgement, has stated that income of the foreign companies could not be taxed by the tax authorities by attributing it to BPO operations based out of India.
However, a foreign company can avoid paying tax in India, if it is compensating the outsourcing unit on an arms length basis.
In its judgement, the Supreme Court upheld the judgement of the Authority for Advance Rulings, which had stated that MSAS did not constitute a permanent establishment.
Home | About Us | Terms and Conditions | Contact Us
Copyright 2016 CAinINDIA All Right Reserved.
Designed and Developed by Binarysoft Technologies Pvt. Ltd.
Binarysoft Technologies - Achievements

Transfer Pricing | International Taxation | Business Consulting | Corporate Compliance and Consulting | Assurance and Risk Advisory | Indirect Taxes | Direct Taxes | Transaction Advisory | Regular Compliance and Reporting | Tax Assessments | International Taxation Advisory | Capital Structuring | Withholding tax advisory | Expatriate Tax Reporting | Litigation | Badges | Club Badges | Seals | Military Insignias | Emblems | Family Crest | Software Development India | Software Development Company | SEO Company | Web Application Development | MLM Software | MLM Solutions