OECD - Page 2

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 |

Two pillar solution to tax challenges for digital economy- Part 1

Two-pillar solution for Tax challenges arising from Digitalisation of Economy and consensus of majority of OECD/ G20 member countries (including India)  Executive summary Certainty is one of the basic cannons of taxation. With the globalisation of economy when Multi National Enterprises (MNEs) starting setting up businesses across the gl...

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Posted Under: Income Tax |

India joins OECD/G20 Inclusive Framework tax deal

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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Posted Under: Income Tax |

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 |

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