Clarification of India’s position on the acceptance of MAP and bilateral APA in cases of countries where Article 9(2) of OECD Model Tax Commentary is absent
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....larification of India’s position on the acceptance of MAP and bilateral APA in cases of countries where Article 9(2) of OECD Model Tax Commentary is absent <br>News and Press Release<br>Dated:- 27-1....
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....1-2017<br><BR>A number of references have been received from time to time regarding the acceptance of applications pertaining to Transfer Pricing MAP cases and Bilateral Advance Pricing Agreements (AP....
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....As) where the Associated Enterprise (AE) of the Indian entity is resident of a country with which India has entered into a Double Taxation Avoidance Agreement (DTAA) but the Agreement does not contain....
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.... Paragraph 2 of Article 9 (or its relevant equivalent Article) relating to 'Corresponding Adjustment'. The matter has been examined by the Central Board of Direct Taxes (CBDT) and it has been decided....
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.... to accept Transfer Pricing MAP and bilateral APA applications regardless of the presence or otherwise of Paragraph 2 of Article 9 (or its relevant equivalent Article) in the DTAAs.<BR> News - Press r....
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....elease - PIB....


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