CBDT outlines recommended approaches to deal with rulings exchanged under BEPS Action 5

Nov 28,2018

CBDT’s FT&TR division releases guidance on 5 types of rulings received from other jurisdictions under BEPS Action 5; The guidance outlines recommended approaches to deal with: 1) rulings relating to preferential regimes, 2) unilateral APAs or other cross-border unilateral rulings in respect of transfer pricing, 3) cross-border rulings providing for a downward adjustment of taxable profits, 4) permanent establishment (PE) rulings and 5) related party conduit ...


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