Income Tax - OECD transfer pricing guidelines for multinational enterprises and tax administrations 2022 Base erosion and profit shifting, the historic global initiative where over 135 countries and tax jurisdictions are collaborating on the implementation of 15 measures to tackle tax avoidance, improve the coherence of international tax rules and ens...
Read MoreIncome Tax - The stage is set to catch hold the shifting of profit from high tax jurisdiction to low tax jurisdiction. Yes, the reading is correct, the OECD embarked upon another pioneering journey to introduce a concept of global minimum tax, called Pillar 2. The objective behind the introduction of pillar 2 is that each jurisdiction levies […...
Read MoreIncome Tax - First time a direct tax is being introduced for businesses in the UAE as earlier there was no tax as per the laws of the country. Ministry of Finance of UAE has introduced Federal corporate tax which will be effective for financial year starting on or after 1st June 2023. In this post is discussed […]...
Read MoreIncome Tax - The main object of international taxation is how to manage cross boarder taxation of a commercial transaction or taxable income which involves more than one country. A system is created mutually by different countries to share the international tax base by assigning tax jurisdiction, preventing tax avoidance, facilitating international tr...
Read MoreIncome Tax - Article explains What is Mutual Agreement Procedures (MAP), Why do countries need MAP, Who can initiate MAP and how, Who can’t access MAP, What are the differences between MAP provisions under OECD and UN Model Conventions, Recent Statistics of MAP Cases and What does Action Plan of BEPS say about MAP? Introduction In digital tax [&hell...
Read MoreIncome 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...
Read MoreIncome 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....
Read MoreIncome 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....
Read MoreIncome 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...
Read MoreIncome 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 ...
Read MoreBlackstone FP Capital Partners Mauritius V Ltd Vs DCIT (ITAT Mumbai) - It is not at the whim or fancy of a tax authority to decide as to what constitutes 'beneficial ownership'; it is absolutely fundamental that as what constitutes beneficial ownership must also be examined and categorical findings are given as to how these requirements of beneficial ownership are sati...
Read MoreABB 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....
Read MorePoonam 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....
Read MorePR 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: ...
Read MoreF. 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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Blackstone FP Capital Partners Mauritius V Ltd Vs DCIT (ITAT Mumbai) -