90 practical questions mapped to the hub framework.
| ID | Question | Finin2min answer |
|---|---|---|
| INQ001 | Does a foreign vendor automatically pay tax in India? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| INQ002 | Can a treaty reduce domestic withholding? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| INQ003 | Is a tax residency certificate alone sufficient? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| INQ004 | What replaces Form 3CEB under the Income-tax Rules, 2026? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| INQ005 | Can safe harbour and MAP both apply to the same accepted transaction? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| INQ006 | When can a subsidiary become a permanent establishment? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| INQ007 | How is foreign tax credit evidenced? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| INQ008 | What is a deemed international transaction? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| INQ009 | Can an APA cover earlier years? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| INQ010 | Does a guarantee create transfer-pricing exposure? | Use the relevant module, statutory anchor and official source. The answer depends on facts and effective date. |
| INQ011 | What is the first check for residence, source and cross-border tax nexus? | Map the legal person, tax residence and beneficial owner. |
| INQ012 | Which law governs residence, source and cross-border tax nexus? | Residence rules and source provisions under the Income-tax Act, 2025; Section 159 treaty framework; Applicable DTAA and protocol |
| INQ013 | What documents support residence, source and cross-border tax nexus? | Contract and statement of work, Tax residency certificate and prescribed declaration, Invoice, payment and remittance documents, Technical architecture and access-rights note |
| INQ014 | What is a common risk in residence, source and cross-border tax nexus? | Relying only on invoice description |
| INQ015 | Give a practical example of residence, source and cross-border tax nexus. | An Indian company pays a Singapore vendor for a cloud platform. The label “subscription” does not decide tax. The rights granted, hosting model, access to source code, service content, payer location and treaty article must be reviewed together. |
| INQ016 | What is the first check for permanent establishment and business connection? | Test fixed place, service, construction, installation, agency and digital nexus separately. |
| INQ017 | Which law governs permanent establishment and business connection? | Domestic business-connection and source provisions; Relevant DTAA Article 5 and Article 7; CBDT guidance and binding judgments |
| INQ018 | What documents support permanent establishment and business connection? | Travel calendar, Organisation and reporting lines, Office/site access evidence, Contracts and revenue attribution working |
| INQ019 | What is a common risk in permanent establishment and business connection? | Counting days without treaty-specific rules |
| INQ020 | Give a practical example of permanent establishment and business connection. | A foreign engineering company sends specialists to India for repeated project visits. Travel days, project duration, site control, subcontracting and treaty-specific service-PE language may alter the result. |
| INQ021 | What is the first check for royalty, software and technical services? | Separate software copy/use from transfer of copyright rights. |
| INQ022 | Which law governs royalty, software and technical services? | Domestic royalty and fee-for-technical-services definitions; Relevant DTAA royalty/FTS article; Supreme Court ruling in Engineering Analysis and subsequent law |
| INQ023 | What documents support royalty, software and technical services? | Licence agreement, End-user restrictions, Architecture note, Treaty and protocol file |
| INQ024 | What is a common risk in royalty, software and technical services? | Copying old opinions without checking contract rights |
| INQ025 | Give a practical example of royalty, software and technical services. | A licence permits internal use of standard software with no right to reproduce, modify or commercially exploit it. The agreement, actual deployment and treaty wording—not the product name—drive the analysis. |
| INQ026 | What is the first check for non-resident withholding and remittance controls? | Create a payment taxonomy and approval matrix. |
| INQ027 | Which law governs non-resident withholding and remittance controls? | Non-resident withholding provisions under the Income-tax Act, 2025; Income-tax Rules, 2026 and remittance forms; Applicable DTAA |
| INQ028 | What documents support non-resident withholding and remittance controls? | Vendor tax pack, Tax memo, Form/certificate trail, Bank remittance evidence |
| INQ029 | What is a common risk in non-resident withholding and remittance controls? | Applying treaty rate without documents |
| INQ030 | Give a practical example of non-resident withholding and remittance controls. | A contract says the vendor must receive USD 100,000 net of Indian taxes. The gross-up can materially change project cost and must be modelled before signature. |
| INQ031 | What is the first check for dtaa, mli and treaty entitlement? | Start with domestic law, then treaty. |
| INQ032 | Which law governs dtaa, mli and treaty entitlement? | Section 159; Applicable DTAA and protocol; Multilateral Instrument positions |
| INQ033 | What documents support dtaa, mli and treaty entitlement? | TRC and prescribed form, Ownership chart, Board and substance evidence, MLI/treaty analysis |
| INQ034 | What is a common risk in dtaa, mli and treaty entitlement? | Using an online treaty rate table as final law |
| INQ035 | Give a practical example of dtaa, mli and treaty entitlement. | A holding company claims a reduced dividend rate. Substance, decision-making, funding, beneficial ownership and treaty anti-abuse provisions must be assessed, not just the certificate of residence. |
| INQ036 | What is the first check for foreign tax credit and double-tax relief? | Map foreign income to Indian heads and tax year. |
| INQ037 | Which law governs foreign tax credit and double-tax relief? | Income-tax Act, 2025 double-tax relief provisions; Income-tax Rules, 2026 foreign-tax-credit procedure and forms; Applicable treaty |
| INQ038 | What documents support foreign tax credit and double-tax relief? | Foreign return, Tax certificate, Payment evidence, Income reconciliation |
| INQ039 | What is a common risk in foreign tax credit and double-tax relief? | Claiming gross foreign withholding without limitation |
| INQ040 | Give a practical example of foreign tax credit and double-tax relief. | An Indian employee receives overseas stock compensation on which foreign tax is withheld. Vesting, exercise, sale and residency periods may split the income and credit across jurisdictions. |
| INQ041 | What is the first check for transfer pricing scope and associated enterprises? | Map direct and indirect ownership. |
| INQ042 | Which law governs transfer pricing scope and associated enterprises? | Sections 161–164; Income-tax Rules, 2026; Form 48 under section 172 |
| INQ043 | What documents support transfer pricing scope and associated enterprises? | Group chart, Intercompany agreements, Ledger extraction, Related-party and guarantee register |
| INQ044 | What is a common risk in transfer pricing scope and associated enterprises? | Testing only the 26% shareholding condition |
| INQ045 | Give a practical example of transfer pricing scope and associated enterprises. | An Indian distributor buys from an unrelated manufacturer, but pricing and supply terms are agreed between the manufacturer and the distributor’s overseas parent. The deemed-transaction rule may require TP reporting. |
| INQ046 | What is the first check for functional analysis and tested-party selection? | Interview operating teams, not only tax personnel. |
| INQ047 | Which law governs functional analysis and tested-party selection? | Sections 161 and 165; Income-tax Rules, 2026 comparability provisions; OECD materials as persuasive guidance |
| INQ048 | What documents support functional analysis and tested-party selection? | Interview notes, Decision matrix, Asset/IP register, Risk-control evidence |
| INQ049 | What is a common risk in functional analysis and tested-party selection? | Template FAR copied year to year |
| INQ050 | Give a practical example of functional analysis and tested-party selection. | An Indian captive is described as “low-risk,” but it negotiates customers, controls credit and develops local marketing intangibles. The contract and actual conduct require reconciliation. |
| INQ051 | What is the first check for arm’s-length methods and economic analysis? | Define the controlled transaction accurately. |
| INQ052 | Which law governs arm’s-length methods and economic analysis? | Section 165; Income-tax Rules, 2026 method and comparability rules; Government notifications on tolerance range where applicable |
| INQ053 | What documents support arm’s-length methods and economic analysis? | Search strategy, Comparable set, Adjustment workbook, Method-rejection memo |
| INQ054 | What is a common risk in arm’s-length methods and economic analysis? | Choosing TNMM by default |
| INQ055 | Give a practical example of arm’s-length methods and economic analysis. | A contract manufacturer with reliable third-party product prices may support CUP; a routine service provider without comparable prices may require a profit-based method. |
| INQ056 | What is the first check for documentation, form 48 and audit trail? | Create a transaction-to-ledger reconciliation. |
| INQ057 | Which law governs documentation, form 48 and audit trail? | Sections 171 and 172; Rules 78–85 and Form 48 under the Income-tax Rules, 2026; Transition/savings under section 536 |
| INQ058 | What documents support documentation, form 48 and audit trail? | Form 48 working, Ledger reconciliation, TP study, Management representation |
| INQ059 | What is a common risk in documentation, form 48 and audit trail? | Using legacy Form 3CEB references for Tax Year 2026-27 |
| INQ060 | Give a practical example of documentation, form 48 and audit trail. | A company’s ledger shows management fees of ₹6 crore, while the agreement and TP report show ₹5.6 crore. The ₹40 lakh difference must be resolved before filing. |
| INQ061 | What is the first check for safe harbour rules? | Confirm eligible assessee and transaction. |
| INQ062 | Which law governs safe harbour rules? | Section 167; Rules 86–93; Form 49 and related statements |
| INQ063 | What documents support safe harbour rules? | Eligibility memo, Form 49, Margin computation, Annual option tracker |
| INQ064 | What is a common risk in safe harbour rules? | Assuming safe harbour eliminates all documentation |
| INQ065 | Give a practical example of safe harbour rules. | A captive service provider should compare safe-harbour margin, expected comparable range, cash tax, MAP access and documentation burden before opting. |
| INQ066 | What is the first check for advance pricing agreements and rollback? | Choose unilateral, bilateral or multilateral route. |
| INQ067 | Which law governs advance pricing agreements and rollback? | Sections 168–169; Rules 105–120 and Forms 50–54; CBDT APA programme guidance |
| INQ068 | What documents support advance pricing agreements and rollback? | APA application pack, Critical-assumption dashboard, Annual compliance report, Rollback analysis |
| INQ069 | What is a common risk in advance pricing agreements and rollback? | Treating APA as a negotiation disconnected from actual conduct |
| INQ070 | Give a practical example of advance pricing agreements and rollback. | A multinational with recurring software-development services may use a bilateral APA where corresponding relief and double-tax certainty justify the longer process. |
| INQ071 | What is the first check for mutual agreement procedure? | Identify the treaty breach and competent authorities. |
| INQ072 | Which law governs mutual agreement procedure? | Rule 121 and Form 55; Applicable DTAA MAP article; CBDT MAP guidance |
| INQ073 | What documents support mutual agreement procedure? | MAP request, Tax assessment orders, TP reports for both countries, Double-tax computation |
| INQ074 | What is a common risk in mutual agreement procedure? | Missing treaty time limit |
| INQ075 | Give a practical example of mutual agreement procedure. | A foreign tax authority increases the parent’s income for an intercompany service charge. The Indian entity may seek corresponding relief through MAP while protecting domestic appeal rights. |
| INQ076 | What is the first check for master file and country-by-country reporting? | Determine constituent-entity and group-reporting status. |
| INQ077 | Which law governs master file and country-by-country reporting? | Section 511; Rules 123–124; Forms 56–60 |
| INQ078 | What documents support master file and country-by-country reporting? | Group structure, Consolidated financials, Master file, CbCR reconciliation |
| INQ079 | What is a common risk in master file and country-by-country reporting? | Threshold calculation errors |
| INQ080 | Give a practical example of master file and country-by-country reporting. | If the Indian entity says it owns local marketing intangibles but the master file says all market development is centrally controlled, the inconsistency can trigger scrutiny. |
| INQ081 | What is the first check for interest limitation and cross-border financing? | Identify direct and deemed AE debt. |
| INQ082 | Which law governs interest limitation and cross-border financing? | Section 177; Transfer-pricing provisions; Applicable treaty and FEMA borrowing framework |
| INQ083 | What documents support interest limitation and cross-border financing? | Loan agreement, Guarantee, Interest model, Credit analysis |
| INQ084 | What is a common risk in interest limitation and cross-border financing? | Looking only at legal lender identity |
| INQ085 | Give a practical example of interest limitation and cross-border financing. | An overseas parent guarantees a third-party loan to its Indian subsidiary. The debt may be treated as AE-supported for interest-limitation purposes and may also require guarantee benchmarking. |
| INQ086 | What is the first check for gaar, treaty anti-abuse and substance? | Document commercial objective before execution. |
| INQ087 | Which law governs gaar, treaty anti-abuse and substance? | GAAR provisions under the Income-tax Act, 2025; Treaty principal-purpose and limitation provisions; Section 536 transition where relevant |
| INQ088 | What documents support gaar, treaty anti-abuse and substance? | Commercial rationale memo, Board papers, Employee/substance evidence, Alternative analysis |
| INQ089 | What is a common risk in gaar, treaty anti-abuse and substance? | Post-facto board minutes |
| INQ090 | Give a practical example of gaar, treaty anti-abuse and substance. | A conduit entity inserted shortly before a sale, with no decision-makers or risk, requires much deeper review than a long-standing operating regional headquarters. |
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