By TIOL News Service

NEW DELHI, JULY 13, 2013: TAKING a leaf from the touring Finance Minister, the MoS(R), Mr Jesudasu Seelam, yesterday said that India is keen to provide a suitable mechanism for resolution of tax disputes between the tax department and foreign companies operating in India. In this direction, he said that the Government inserted provisions relating to Advance Rulings vide Finance Act, 1993. In order to bring in certainty and transparency in Transfer Pricing mechanism, scheme of Advance Pricing Agreement (APA) under Transfer Pricing Regulations, has been introduced in the Union Budget of the year 2012 -13, the Minister added.

The Minister was speaking after inaugurating a training programme for the officers of Directorates of International Taxation here yesterday. Dr. Sudha Sharma, Chairperson, CBDT, Mr N.C. Joshi, Director General of Income Tax (International Taxation) and other senior Officers of the Department were also present on the occasion.

But what the Minister did not talk about is the recent transfer of some senior officers from the Foreign Taxation Division of the CBDT, which is being speculated as one of the measures taken by the MoF to further 'reduce' TP disputes. Netizens may recall that even the Finance Minister has been talking about some of the TP-related initiatives taken recently in Washington.

This training programme is being organized, as an in-house training on International Taxation, to enable the officers to effectively administer the provisions of the IT Act, DTAAs and other relevant provisions. This training shall also act as a catalyst for the officers to refresh their knowledge and evolve a coordinated approach on the divergent and highly technical subjects of International Taxation and Transfer Pricing. Similarly, another training programme on Transfer Pricing issues shall also be organized from 25th to 27th July, 2013, wherein, advanced training to the Transfer Pricing Officers (TPOs) shall be imparted.

The Directorate General of International Taxation (DGIT) deals with international taxation issues pertaining to entities having cross border transactions. It encompasses determination of tax on a person or business subject to the tax laws of different countries and Double Taxation Avoidance Agreements (DTAAs). Another primary area of functioning of this Directorate General relates to determination and resolving of issues of Transfer Pricing.

The collection of tax in the Directorate General of International Taxation has grown from Rs. 11,790 cr in FY 2007-08 to Rs. 28,030 in FY 2012-13, an annual increase of more than 27%. Similarly, the adjustments made by the Transfer Pricing Officers (TPOs) have increased from Rs. 3,432 cr in FY 2007-08 to Rs. 70,016 cr. in FY 2012-13.