A Case Study on Direct Taxation

Abstract

Abstract M/S Shell India and Shell Gas BV The transfer pricing has a significant role to play in terms of taxation of income from intangibles in case of intercompany transfer pricing, in today’s world. With special reference to the Shell case which is a wholly owned subsidiary of the Royal Dutch Shell Group. The Royal Dutch Shell Group was created in February 1907 through the amalgamation of two rival companies: Royal Dutch Petroleum Company and the ‘Shell’ Transport and Trading Company Ltd of the United Kingdom. The Issue of Direct Taxation laws as applicable for operations carried out by businesses from located in India as also the transfer pricing Issue are creating lots of heart burn and legal tangles for global organization having subsidiaries in India. The Government at the centre in India is attending to major such tax issues based on the impact of retrospective taxation as adopted by the current and earlier Governments. This aspect of direct taxation has affected in some cases the opportunities for attracting Foreign Direct Investments and ease of doing business in India for many global companies desirous of establishing business subsidiaries in India.