Navigating Global Tax Challenges: Key International Tax & Transfer Pricing Updates – July 2024
As multinational operations continue to evolve, staying compliant with international tax and transfer pricing regulations has never been more critical. The July 2024 edition of CNK & Associates LLP’s International Tax & TP Quarterly Insights highlights pivotal legal developments shaping cross-border tax policy, offering timely guidance for tax professionals, CFOs, and global business leaders.
This issue focuses on several important rulings impacting transfer pricing, beneficial ownership, tax treaty benefits, and arm’s length principles. Notable cases include:
The Mumbai Tribunal’s clarification on interest-free quasi-equity loans to foreign subsidiaries and their treatment under Indian transfer pricing rules.
The Delhi High Court upholding the use of internal comparables under the Transactional Net Margin Method (TNMM) despite volume discrepancies.
A reaffirmation of beneficial ownership in the context of Cyprus-India tax treaty benefits for investment income.
The Supreme Court’s dismissal of a review petition on software royalty classification, reinforcing that software licensing under EULA does not constitute royalty under Indian tax law.
These decisions provide strategic clarity on tax planning, cross-border investments, and the use of tax treaties—making this update a must-read for those managing international taxation.
