As we close the chapter of 2025 and step into the promising year of 2026, I convey my warm greetings and sincere wishes for a happy, successful, and fulfilling New Year to all our readers.
The New Year brings fresh opportunities to build upon the strong foundation already laid. With renewed determination and optimism, I am confident that the journey ahead will lead to continued progress and greater success.
The first article discusses specialised transfer pricing situations that require careful evaluation in determining whether related party transactions satisfy the arm’s length principle. It focuses on financial transactions, intra-group services, and intangibles, highlighting the key factors relevant for benchmarking, cost allocation, documentation, and determination of arm’s length compensation in such sensitive arrangements.
The second article analyses an important decision of the Hon’ble National Company Law Tribunal concerning reduction of share capital by cancellation of shares held through a trust arrangement. It discusses the legal permissibility of selective reduction under Section 66 of the Companies Act, 2013, the treatment of shares not represented by available assets, and the impact of the statutory restriction under Section 232(3)(b) relating to trust-held shares. The article also reviews the judicial principles that reduction of capital is primarily a matter of domestic concern, subject to fairness and creditor protection. It highlights how the Tribunal approved the capital reduction after examining compliance, shareholder consent, and the absence of prejudice to creditors.
Lastly, CBDT notifications for the month of December 2025 has been included in this wiki to ensure continual updating with the latest regulatory developments.
Key Topics:
- Transfer pricing in UAE – Part VI
- Reduction of share capital on a selective basis – Is it permissible?
- CBDT notifications for the month of December 2025
