Wednesday, January 27, 2016
Transfer of shares of an Indian Co by a Mauritius entity to a Singapore entity due to group reorganization is not a scheme for avoidance of tax. The capital gains are exempt under India-Mauritius DTAA. Treaty shopping is permissible. A ROI u/s 139(1) need not be filed if income is exempt from tax
Dow IMEA Group was dismantled in 2010 and that is how the need for realignment of the group arose whereby DAS entity was to be shifted from an entity which falls under Europe region to an entity which would fall in the Asia-Pacific region. This was to be done with a view to achieve better control. Singapore is one of the upcoming countries in Asia-Pacific region in the opinion of the applicant and therefore, the Dow group contemplated to shift the share holding of DAS India from Mauritius to Singapore. All this exercise is also more than 5 years old from the date of the last acquisition of the shares. Thus, it cannot be said that the proposed transfer of shares was amounting to a scheme to avoid payment of taxes in India. It was clearly for the business considerations. We, therefore, reject the contention of the Revenue that this amounting to a scheme to avoid payment of taxes in India. We accept the contention raised by the applicant about its not having a PE in India
Wednesday, January 20, 2016
The collapse in crude prices also caused the ruble to nosedive to a record low today as the oil plunge weighed on the Russian economy and surpassed every other obstacle the nation has endured including crippling sanctions. The currency fell 1.8% to 80.156 against the dollar, breaching a threshold it last crossed during the ruble crisis of December 2014 that forced the central bank to intervene through a series of emergency rate increases. MICEX -1.6%.
Crude futures are getting slammed again, with U.S. oil falling to its lowest since September 2003 on worries about a global glut. The drop comes after the International Energy Agency, which advises industrialized countries on energy policy, warned on Tuesday that oil markets could "drown in oversupply". Stocks data from the American Petroleum Institute is due later today, while official figures from the Energy Information Administration will be released tomorrow. WTI -2.3% to $27.80/bbl; Brent -2.3% to $28.09/bbl.
Thursday, January 14, 2016
Almost $3.2T has been wiped off global stocks since the start of 2016, driven by renewed jitters over China's economy and a slump in energy prices, pushing all major U.S. indexes into correction or bear market territory. Asian markets (except for China) and European bourses are keeping up the trend today after a bruising session on Wall Street that saw the S&P 500 drop 2.5% and the Nasdaq tank 3.4%. Despite looking for a comeback earlier, U.S. futures have also dipped into the sea of red.
Monday, January 11, 2016
Oil prices are sharply lower to start off the week as concerns over demand from China impact trading again, along with some fresh worries. Morgan Stanley is the latest major investment firm to forecast oil prices could fall into the $20s with the U.S. dollar continuing to strengthen against major currencies. There is also news that Saudi Arabia is considering an IPO for its state oil company, a development that adds a new layer of anxiety with traders. Brent crude is down 1.42% to $32.69, while WTI crude futures are 1.6% lower at $32.62.
Thursday, January 7, 2016
According to the World Bank, the global economy will sputter along this year as China's slowdown prolongs a commodity slump and contractions endure in Brazil and Russia. As a result, the international institution cut its forecasts for the third straight year, predicting 2016 growth to fall by 0.4 percentage point to 2.9%. With regards to the U.S., the World Bank decreased its 2016 prospects to 2.7%, down from 2.8 percent from June, citing the dampening effect on exports from the surging dollar.
Monday, January 4, 2016
Manufacturing in the eurozone accelerated at the fastest pace in 20 months in December, with every country clocking in output growth and job creation (even Greece!). Markit's eurozone manufacturing PMI edged up to 53.2 from 53.1 in November, as the ECB's unprecedented stimulus reached companies and households.