If a person is a resident in both the Contracting States, tie-breaker test is used.
(i) place of habitual abode;
(ii) country of nationality; (iii) availability of permanent home; (iv) place where personal & economic interest closer. Correct secquence is
(i) place of habitual abode;
(ii) country of nationality; (iii) availability of permanent home; (iv) place where personal & economic interest closer. Correct secquence is
Anonymous Quiz
19%
(i), (iii), (ii) and (iv)
19%
(iv), (i), (iii) and (ii)
44%
(iii), (iv), (i) and (ii)
19%
(i), (ii), (iii) and (iv)
Most of the Tax Treaties entered in to by India are based on the following model:
Anonymous Quiz
14%
US Model
41%
OECD Model
34%
UN Model
10%
G20 Model
In order to invoke the provisions of a Tax Treaty for a person who is a dual resident, which rule is applied to resolve the issue?
Anonymous Quiz
8%
Non-discrimination rule
11%
Controlled foreign corporation rule
73%
Tie-breaker rule
7%
Force of attraction rule
Which of the following Section of Income-tax Act, 1961, governing presumptive taxation of non-resident tax payers, does not deal with profits from operations of ship or aircraft?
Anonymous Quiz
15%
Section 44B
32%
Section 172
25%
Section 44BB
28%
Section 44BBA
What is the full form of โMAPโ which refers to a process of resolution of tax dispute arising between contracting States in relation to interpretation of tax treaties?
Anonymous Quiz
7%
Multi Agreement Procedure
23%
Mutual Agreement Programme
11%
Mutual Arrangement Programme
58%
Mutual Agreement Procedure
A non-resident receives technical fees from the Government of India for the services rendered outside India. He receives it outside India.
Anonymous Poll
31%
Income is deemed to be accrue or arise outside India
52%
Income is deemed to accrue or arise in India
6%
Depends upon the agreement entered by him with the Government
12%
Depends whether he has a PE in India or not
A Ltd. has failed to report an international transaction entered into by it with PQR Inc., which is a associated enterprise of A Ltd. What would be the penalty leviable in this case?
Anonymous Quiz
35%
(a) 2% of the value of the international transaction
9%
(b) 50% of tax payable on under-reported income
28%
(c) 200% of tax payable on under-reported income
28%
(d) Both (a) and (c)
Benefit of presumptive taxation under the Income-tax Act, 1961 would not be available to Mr. Tom, a non-resident, in A.Y. 2021-22, in respect of the related Indian income, if he is engaged in the business of โ
Anonymous Quiz
12%
Operation of ships
7%
Operation of aircraft
38%
Civil construction in connection with an approved turnkey project
43%
Plying, hiring or leasing of goods carriages
Which of the following is not a Specific Anti Avoidance Rules (SAARs)?
Anonymous Quiz
25%
Transfer pricing
18%
Thin capitalization
26%
POEM
30%
Treaty shopping
Under the provisions of the Income Tax Act, 1961, GAAR _____________.
Anonymous Quiz
42%
Overrides tax treaties
23%
Overrides tax treaties only if specifically mentioned in the treaty
11%
Do not override tax treaties
24%
Overrides treaties except for PE & Business Profits provisions
The key objectives of the Country by Country Reporting are:
Anonymous Quiz
28%
(A) To articulate consistent transfer pricing position, across the globe
7%
(B) To assess the need of MNC's to enter into an APA or Safe Harbour option
8%
(C) To determine ALP of International Transaction
58%
(D) Both (B) & (C)
A software developer firm can be selected as comparable under transfer pricing for
Anonymous Quiz
41%
Software Trader firm
24%
BPO service provider firm
7%
Hardware manufacturer firm
27%
None of the above
A Ltd. (India) holds 30% Equity in B Inc. (USA) and 40% Equity in C PLC (UK). Identify the Associated enterprises?
Anonymous Quiz
6%
A Ltd. & B Inc.
7%
A Ltd. and C Plc.
21%
B Inc. & C Plc.
65%
All of the above
Detailed revision of Equalization Levy and Transfer Pricing for Dec 21 Exam uploaded in our YouTube Channel.
https://youtube.com/c/SAKETGHIRIA
https://youtube.com/c/SAKETGHIRIA
Forwarded from CA Final DT CA Saket Ghiria
Transfer Pricing MCQs.pdf
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30 MCQs of Transfer Pricing (CA Final Direct Tax). Covering all regular and case scenario MCQs issued by ICAI.
Channel name was changed to ยซDirect Tax MCQs (CA & CMA Final) ๐ยป
Which of the following Income head restricts same year set-off with other heads upto Rs 2 lakh?
Anonymous Quiz
9%
Speculation Business
77%
House Property
13%
Specified business u/s 35AD
1%
Capital Gain