INTRODUCTION

We are pleased to present the latest edition of Tax Street – our newsletter that covers all the key developments and updates in the realm of taxation in India and across the globe for the month of February 2019.

The Kingdom of Saudi Arabia introduced the transfer pricing regulation, thus marking a new beginning in the international taxation amongst GCC countries.

Apart from this, there have been some crucial announcements and rulings in the areas of direct tax, transfer pricing, and indirect tax. In this issue of Tax Street, we have tried to collect and coalesce all such significant developments to draw a holistic picture of the current tax landscape in India for your understanding.

  • The 'Focus Point' section talks about the Transfer Pricing By-Laws for the Kingdom of Saudi Arabia released by The General Authority of Zakat and Tax (GAZT/Authority) on 15 February 2019.
  • Under the 'From The Judiciary', we provide in brief, the key rulings on important cases, and our take on the same.
  • Our 'Tax Talk' provides key updates on the important tax-related news from India and across the globe.
  • Under 'Compliance Calendar', we list down the important due dates with regard to direct tax, transfer pricing, and indirect tax in the month.

We hope you find our newsletter useful and we look forward to your feedback. You can write to us at taxstreet@skpgroup.com. We would be happy to hear your thoughts on what more can we include in our newsletter and incorporate your feedback in our future editions.

FOCUS POINT

Final Transfer Pricing By-Laws issued by Saudi Arabia

The General Authority of Zakat and Tax (GAZT/Authority) has released the final transfer pricing By-Laws for the Kingdom of Saudi Arabia (KSA) on 15 February 2019. This marks a new beginning in the international taxation amongst the Gulf Cooperation Council (GCC) countries. We have summarized the newly introduced By-laws in three broad categories:

  • Discussions on the applicability of By-Laws and meaning assigned to the relevant terms
  • Compliances triggered along with a deadline and corresponding monetary thresholds
  • Other important points for consideration in question and answers format

Applicability: The transfer pricing By-Laws are applicable to all persons, except persons who are subject only to Zakat. Also, Country-by-Country Reporting (CbCR) related compliance would be applicable to all persons regardless of whether that person or entity is subject to only income tax, zakat or both.

Controlled Transactions: All transactions involving Related Persons or Persons Under Common Control, including notional transaction and transactions with Permanent Establishment

Related persons for Companies, Partnership Firm, etc., will include Person Under Common Control (i.e., Sister concerns) and where a person (alone or together with a Related Person) has "effective control" over the other person. Furthermore, the term "Effective Control" has been given a very comprehensive definition to include various situations.

Download >> Tax Street - February 2019

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.