OECD

Examining the GloBE: OECD’s proposal for global minimum tax

Income Tax - The taxation of the digital economy was first on the Organization for Economic Co-operation and Development (OECD) list of 15 Base Erosion and Profit Shifting (BEPS) Action items. BEPS Action Plan 1 was announced in 2013 in which it had partially addressed the challenges that would be faced by the digital economy....

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Need of CFC legislation in India

Income Tax - There is a great need and importance of introducing CFC i.e. controlled foreign corporation legislation in Indian tax law, as it is one of the biggest measures to avoid payment of income tax in India by the resident persons of India. In the current scenario, there are no such provisions existing in income tax act, […]...

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Need of Controlled Foreign Corporations (CFC) legislation in India

Income Tax - There is a great need and importance of introducing CFC i.e. controlled foreign corporation legislation in Indian tax law, as it is one of the biggest measures to avoid payment of income tax in India by the resident persons of India. In the current scenario, there are no such provisions existing in income tax act, […]...

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Preparatory & Auxiliary activities in Permanent Establishment: How does India cope with the dearth in determining provisions?

Income Tax - With the incessant global growth, the relevance of Permanent Establishment (PE) in international taxation has become paramount. In simpler terms, the expression ‘Permanent Establishment’ means a fixed place of business through which the business of an enterprise is wholly or partly carried on....

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Understanding OECD’s Two-Pillar Approach

Income Tax - In this dynamic era, the brick and mortar business models are turning digital and Multi-National Companies (MNCs) are effectively operating out of various jurisdictions without having a physical presence. From a taxation perspective, it is way more challenging when the value creation, income generation and the adjoining taxability cut acr...

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CBDT releases MLI synthesised text for India-Czechoslovak Socialist Republic tax treaty

Income Tax - CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SLOVAK REPUBLIC AGREEMENT FOR AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF FISCAL EVASION WITH – SLOVAK REPUBLIC Whereas a Agreement between the Government of th...

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CBDT releases MLI synthesised text for India-Poland tax treaty

Income Tax - CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE REPUBLIC OF POLAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND ...

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CBDT releases MLI synthesised text for India-Australia tax treaty

Income Tax - CBDT has released the synthesised text for India-Australia tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. AUSTRALIA SYNTHESISED TEXT  OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAXT REATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN ...

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CBDT releases MLI synthesised text for India-Singapore tax treaty

Income Tax - CBDT has released the synthesised text for India-Singapore tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNME...

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CBDT releases MLI synthesised text for India-Austria tax treaty

Income Tax - CBDT has released the synthesised text for India-Austria tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. AUSTRIA SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE CONVENTION BETWEEN THE G...

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ITAT – taking virtual reality a bit too seriously ?

ABB FZ - LLC, Bangalore Vs. Dy.DIT, Bangalore (ITAT Bangalore) - A reader should be able to come to his / her own conclusion by applying the legislative enactments and judicial pronouncements to the facts of the case. While re-producing any portion of legislative enactment or judicial pronouncement, it is para phrased and emphasis is supplied by way of underline....

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No bar Under OECD to provide document relied to Appellant; Mere showing of document not sufficient

Poonam Jain Vs Union of India & Ors. (Delhi High Court) - High Court held that to say that the person being prosecuted or proceeded against can only be 'shown' such documents, but not provided copies thereof is untenable even on a plain reading of Article 26 (2) of the OECD Model Convention....

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SEBI Meeting on Implementation of OECD Principles of Corporate Governance, Spot Price Determination of Commodities etc.

PR No. 297/2015 - (23/12/2015) - PR No. 297/2015 Sixth Meeting of the International Advisory Board of SEBI The Sixth meeting of the International Advisory Board (IAB) of the Securities and Exchange Board of India (SEBI) was held on December 21 & 22, 2015. The following major issues were inter alia discussed during the meeting: ...

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Guidance on Implementation on FATCA and CRS

F. No. 500/137/2011-FTTR-III - (31/08/2015) - To combat the problem of offshore tax evasion and avoidance and stashing of unaccounted money abroad requiring cooperation amongst tax authorities, the G20 and OECD countries working together developed a Common Reporting Standard (CRS) on Automatic Exchange of Information (AEOI). The CRS on AEOI was...

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Recent Posts in "OECD"

Examining the GloBE: OECD’s proposal for global minimum tax

The taxation of the digital economy was first on the Organization for Economic Co-operation and Development (OECD) list of 15 Base Erosion and Profit Shifting (BEPS) Action items. BEPS Action Plan 1 was announced in 2013 in which it had partially addressed the challenges that would be faced by the digital economy....

Read More
Posted Under: Income Tax |

Need of CFC legislation in India

There is a great need and importance of introducing CFC i.e. controlled foreign corporation legislation in Indian tax law, as it is one of the biggest measures to avoid payment of income tax in India by the resident persons of India. In the current scenario, there are no such provisions existing in income tax act, […]...

Read More
Posted Under: Income Tax |

Need of Controlled Foreign Corporations (CFC) legislation in India

There is a great need and importance of introducing CFC i.e. controlled foreign corporation legislation in Indian tax law, as it is one of the biggest measures to avoid payment of income tax in India by the resident persons of India. In the current scenario, there are no such provisions existing in income tax act, […]...

Read More
Posted Under: Income Tax |

Preparatory & Auxiliary activities in Permanent Establishment: How does India cope with the dearth in determining provisions?

With the incessant global growth, the relevance of Permanent Establishment (PE) in international taxation has become paramount. In simpler terms, the expression ‘Permanent Establishment’ means a fixed place of business through which the business of an enterprise is wholly or partly carried on....

Read More
Posted Under: Income Tax |

Understanding OECD’s Two-Pillar Approach

In this dynamic era, the brick and mortar business models are turning digital and Multi-National Companies (MNCs) are effectively operating out of various jurisdictions without having a physical presence. From a taxation perspective, it is way more challenging when the value creation, income generation and the adjoining taxability cut acr...

Read More
Posted Under: Income Tax |

GAAR and PPT: Beginning of a new era of co-existence?

The global tax landscape is constantly evolving to keep pace with ever-changing business models and structures. Introduction of the Base Erosion and Profit Shifting (BEPS) project by OECD/G-20 in the year 2016 was one such significant international stepsince the advent of bilateral tax treaties, wherein more than 100 countries collaborate...

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Posted Under: Income Tax |

MAP Guidance Issued By CBDT As Recommended By OECD

INTRODUCTION: > Any country suffering disputes with respect to Transfer Pricing adjustments, Existence of a Permanent Establishment, Attribution of profits to a Permanent Establishment, Characterisation or re-characterisation of an income or expense lead, on being result taken, by legal or administrative authorities as per domestic law...

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Posted Under: Income Tax |

CbCR- Advanced Analysis

In this article you will find detailed analysis of certain terms and issues which either OECD or certain other countries have clarified. Notification in respect of BEPS Action plan 13 is expected shortly from CBDT. ...

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Posted Under: Income Tax |

CBCR: Why Such Reporting, By Whom, When, What Are the Difficulties and Benefits

CbCR (Country by Country Report) is one of the recent amendment which has created a lot of hue and cry in the industry, hence here in this article the author will provide the basic concepts related to CbC reporting for all the Chartered Accountants. ...

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Posted Under: Income Tax |

OECD’s Unified Approach on Pillar One to Address the Challenges Arising from Digitalization of Economy: A Critical Analysis

This article provides a comprehensive summary of the efforts undertaken by OECD in addressing the issues relating to the Tax Challenges Arising from the Digitalisation of the Economy. The article then discusses the intricacies of the proposed Unified Approach issued by OECD Secretariat and endorsed by the OECD Inclusive Framework on Base ...

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Posted Under: Income Tax |

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