OECD articles

Equalisation Levy | Complete Provisions for Your Easy Understanding

Due Date for furnishing Statement under ‘Equalisation Levy’ (EL) for FY 2020-21 is 30.06.2021 || Compilation of Complete Provisions For Your Easy Understanding A. Brief Background The Organisation for Economic Co-operation and Development (OECD) through the Base Erosion and Profit Shifting (BEPS) project under Action Plan 1 re...

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Posted Under: Income Tax |

How Does Thin Capitalization Affect Taxation? 

Organization for Economic Cooperation and Development (OECD) and the (G20) countries have launched an initiative known as base erosion and profit shifting (BEPS), which consists mostly of tax avoidance methods. These techniques primarily aim to fill in and make accommodations for tax policy loopholes, which aid in leveraging such gaps in ...

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Posted Under: Income Tax |

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....

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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, […]...

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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, […]...

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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....

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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...

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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 |

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