https://www.taxtmi.com/circulars?id=57814 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. en-us Thu, 22 Nov 2018 00:00:00 +0530 Thu, 29 Nov 2018 17:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=57814 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. Circulars Income Tax Thu, 22 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/circulars?id=57814