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OECD

Why are Tax Information Exchange Agreements the need of the hour?

Income Tax - Tax Information Exchange Agreements (TIEA) are agreements developed by the Organization for Economic Co-operation and Development (OECD). The purpose of the TIEAs was mainly to reduce the harmful tax practices.  They also seek to facilitate international cooperation with the help of exchange of information surrounding tax matters such as...

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Role of Working Capital Adjustments in Transfer Pricing

Income Tax - Transfer pricing provisions was incorporated in the Income Tax Act in April 2001 and now it has travel the journey of almost two decades in India. If we give one line principal to the transfer pricing provisions then it is benchmarking of international transactions entered with associated enterprises with comparables transactions (interna...

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International Tax Deal For Digital Age, Finally

Income Tax - With the declaration of final tax system reformation on 10th August 2021, by 136 countries and jurisdictions representing 90% of global GDP, you may be happy to know that Multinational Enterprises (MNEs) will be subject to a minimum 15% tax rate from 2023 and that this deal would embark on distribution of US D 125 […]...

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Nuisance impact of SEP definition on transactions with Non-residents

Income Tax - OECD published a report on the issue of ‘Base Erosion & Profit Shifting’, in which they set out 15 BEPS action plans to tackle the issue of base erosion and profit shifting. Since then OECD and G20 have continued to work on BEPS action through inclusive framework....

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Two pillar solution to tax challenges for digital economy – Part 2

Income Tax - Implementation plan for the two-pillar solution to address tax challenges of a digital economy Background In my earlier article dated July 19, 2021, I have given a brief overview of the Statement on a two‑pillar solution to address the tax challenges arising from the digitalisation of the economy (the Statement) that was agreed by 130 [...

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ICRICT Open letter to G20 Heads of State and Government

Income Tax - Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 billion a year in lost fiscal revenues. After years of negotiations including 140 countries, the agreement announced last Friday shows that it is finally possible to change a system that was built one hundred yea...

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Seychelles’ Tax Inspectors Without Borders programme launched

Income Tax - Tax Inspectors Without Borders (TIWB), a joint initiative of the United Nations Development Programme (UNDP) and the Organisation for Economic Cooperation and Development (OECD), launched its programme in Seychelles on 4th October, 2021. India was chosen as the Partner Administration and has provided Tax Expert for this programme....

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India joins OECD/G20 Inclusive Framework tax deal

Income Tax - Majority of the members OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting(including India)adoptedyesterday ahigh-level statement containing an outline of a consensus solution to address the tax challenges arising from the digitalisation of the economy....

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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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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"

Why are Tax Information Exchange Agreements the need of the hour?

Tax Information Exchange Agreements (TIEA) are agreements developed by the Organization for Economic Co-operation and Development (OECD). The purpose of the TIEAs was mainly to reduce the harmful tax practices.  They also seek to facilitate international cooperation with the help of exchange of information surrounding tax matters such as...

Read More
Posted Under: Income Tax |

Role of Working Capital Adjustments in Transfer Pricing

Transfer pricing provisions was incorporated in the Income Tax Act in April 2001 and now it has travel the journey of almost two decades in India. If we give one line principal to the transfer pricing provisions then it is benchmarking of international transactions entered with associated enterprises with comparables transactions (interna...

Read More
Posted Under: Income Tax |

International Tax Deal For Digital Age, Finally

With the declaration of final tax system reformation on 10th August 2021, by 136 countries and jurisdictions representing 90% of global GDP, you may be happy to know that Multinational Enterprises (MNEs) will be subject to a minimum 15% tax rate from 2023 and that this deal would embark on distribution of US D 125 […]...

Read More
Posted Under: Income Tax |

Nuisance impact of SEP definition on transactions with Non-residents

OECD published a report on the issue of ‘Base Erosion & Profit Shifting’, in which they set out 15 BEPS action plans to tackle the issue of base erosion and profit shifting. Since then OECD and G20 have continued to work on BEPS action through inclusive framework....

Read More
Posted Under: Income Tax |

ICRICT Open letter to G20 Heads of State and Government

Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 billion a year in lost fiscal revenues. After years of negotiations including 140 countries, the agreement announced last Friday shows that it is finally possible to change a system that was built one hundred yea...

Read More
Posted Under: Income Tax |

Two pillar solution to tax challenges for digital economy – Part 2

Implementation plan for the two-pillar solution to address tax challenges of a digital economy Background In my earlier article dated July 19, 2021, I have given a brief overview of the Statement on a two‑pillar solution to address the tax challenges arising from the digitalisation of the economy (the Statement) that was agreed by 130 [...

Read More
Posted Under: Income Tax |

Seychelles’ Tax Inspectors Without Borders programme launched

Tax Inspectors Without Borders (TIWB), a joint initiative of the United Nations Development Programme (UNDP) and the Organisation for Economic Cooperation and Development (OECD), launched its programme in Seychelles on 4th October, 2021. India was chosen as the Partner Administration and has provided Tax Expert for this programme....

Read More
Posted Under: Income Tax |

Transfer Pricing as a means to minimize Tax

Transfer pricing refer to the strategies which determine the trading price for goods or services between the related parties which is defined under  Section 2(76) of Companies act 2016 and covered in AS 18 and IND AS 24. Transfer pricing empowers changes in pricing. Transactions under Transfer pricing between related entities in differen...

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Posted Under: Income Tax |

UN Model Tax Convention Vs. OECD Model Tax Convention: Significance of Distinction

As the world moves increasingly towards economic integration and globalization there is a lot of cross border trade, investment and business which will only increase as more and more developing and least developed countries open up their borders for more business with the international community....

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Posted Under: Income Tax |

Mutual Agreement procedure – OECD Recommendation on Stage 2 Peer Review Reports regarding time limit

The Double Taxation Avoidance Agreement (DTAA), inter alia, provide rules and mechanisms for allocation of taxing rights amongst the treaty partners; avoidance of economic and juridical double taxation; and resolution of taxation not in accordance with the treaty through the Mutual Agreement Procedure (‘MAP’).  MAP is an inbuil...

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Posted Under: Income Tax |

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