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...
Read MoreIncome 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...
Read MoreIncome 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 […]...
Read MoreIncome 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....
Read MoreIncome 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 [...
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 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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