CBDT
The Central Board of Direct Taxes (CBDT) entered into two Unilateral Advance Pricing Agreements (APA) on 4th May, 2017 and 11th May, 2017 respectively, with Indian taxpayers. One of the Agreements also has “Rollback” provision. The APA Scheme endeavours to provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing and determining the arm’s length price of international transactions in advance for the maximum of five future years. Further, the taxpayer has the option to rollback the APA for four preceding years, as a result of which, total nine years of tax certainty is provided. Since its inception, the APA scheme has attracted tremendous interest among Multi National Enterprises (MNEs). The two APAs signed pertain to chip design/development of embedded software and Information technology (software development) sectors of the economy. The number of APAs signed in the current financial year now is four. The CBDT expects more APAs to be signed in the near future.
SEBI
SEBI has issued Securities and Exchange Board of India (International Financial Services Centres) Guidelines, 2015-Permissible investments by Portfolio Managers, AlternateInvestment Funds and Mutual Funds operating in IFSC. Thereby, Clause 9 (4) and Clause 22 (3) of SEBI (IFSC) Guidelines, 2015 are amended. A portfolio manager or any alternative investment fund or mutual fund operating in IFSC shall be permitted to invest in the Securities which are listed in IFSC, Securities issued by companies incorporated in IFSC and Securities issued by companies incorporated in India or companies belonging to foreign jurisdiction subject to such conditions or guidelines that may be stipulated or issued by the Reserve Bank of India and Government of India from time to time. Further, it is clarified that such portfolio manager, alternative investment fund or mutual fund shall invest in India through the foreign portfolio investor route.
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