Spontaneous exchange of rulings identifies cross-border pricing mismatches and informs action to prevent base erosion and profit shifting. Templates received under BEPS Action 5 cover preferential regime rulings, unilateral APAs, cross-border downward profit adjustments, PE rulings and conduit rulings; where Indian residents (ultimate parent, immediate parent, related party, head office, payer or ultimate beneficial owner) are involved, the templates must be used to assess whether economic activity and taxable income in India are commensurate with value creation and to detect pricing mismatches risking base erosion. Additional information may be requested via Exchange of Information and all received information is subject to treaty confidentiality requirements.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Spontaneous exchange of rulings identifies cross-border pricing mismatches and informs action to prevent base erosion and profit shifting.
Templates received under BEPS Action 5 cover preferential regime rulings, unilateral APAs, cross-border downward profit adjustments, PE rulings and conduit rulings; where Indian residents (ultimate parent, immediate parent, related party, head office, payer or ultimate beneficial owner) are involved, the templates must be used to assess whether economic activity and taxable income in India are commensurate with value creation and to detect pricing mismatches risking base erosion. Additional information may be requested via Exchange of Information and all received information is subject to treaty confidentiality requirements.
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