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: ACCOUNTING STANDARD :: due date for vat payment :: VAT RATES :: form 3cd :: VAT Audit :: list of goods taxed at 4% :: Central Excise rule to resale the machines to a new company :: empanelment :: ARTICLES ON INPUT TAX CREDIT IN VAT :: articles on VAT and GST in India :: ICAI offer Get Windows 7,Office 2010 in Rs.799 Taxes :: cpt :: TDS :: ACCOUNTING STANDARDS :: TAX RATES - GOODS TAXABLE @ 4%
 
 
« News Headlines »
 Seven things you must do before 31st March
 Income Tax saving investments: Top 5 options available for high-income individuals
 How to use zero tax rule on long term capital gains on stocks
 GST Returns - Furnishing details of inward supplies
 5 ways to maximise you income tax return
 Income-tax (2nd Amendment) Rules, 2017
 Soon, Faster PAN, An App For Filing Tax Returns
 Changes in income tax return filing process
 New Income Tax Rates And Deductions Applicable From April 1, 2017
 Tax and transparencya
 No decision yet on imposing tax on cash transactions

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 2017 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