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Latest Articles

Country-by-Country Reporting (CbCR)

Income Tax : Country-by-Country Reporting (CbCR) is a crucial component of the transfer pricing documentation requirements introduced by the Or...

March 31, 2024 891 Views 0 comment Print

Introduction to Pillar one Amount B in OECD

Income Tax : Discover how the OECD's introduction of Pillar One Amount B in 2024 streamlines transfer pricing for marketing and distribution, e...

March 3, 2024 588 Views 0 comment Print

Evolution of OECD’s concept of Harmful Tax Practices: From 1998 Report to BEPS Action 5 Approach

Income Tax : Explore the evolution of harmful tax practices from the OECD's 1998 report to the BEPS Action 5 approach, focusing on transparency...

February 21, 2024 297 Views 0 comment Print

Navigating Global Maze: India and New Era of Minimum Corporate Taxation

Income Tax : Explore the impact of OECD's Global Minimum Tax Agreement on India's tax landscape. Uncover challenges, opportunities, and India's...

February 2, 2024 396 Views 0 comment Print

BEPS 2.0: Unpacking Pillar One and Pillar Two Proposals

Income Tax : Dive into BEPS 2.0 with an in-depth analysis of Pillar One & Pillar Two proposals, reshaping international tax. Explore the impact...

December 21, 2023 1539 Views 0 comment Print

Latest News

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 bi...

October 12, 2021 678 Views 0 comment Print

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 ...

October 5, 2021 456 Views 0 comment Print

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-le...

July 2, 2021 429 Views 0 comment Print

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 modif...

March 19, 2020 342 Views 0 comment Print

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 ...

March 19, 2020 639 Views 0 comment Print

Latest Judiciary

It is not at whim or fancy of a Tax authority to decide as to what constitutes beneficial ownership

Income Tax : It is not at the whim or fancy of a tax authority to decide as to what constitutes 'beneficial ownership'; it is absolutely fundam...

June 17, 2022 681 Views 0 comment Print

ITAT – taking virtual reality a bit too seriously ?

Income Tax : A reader should be able to come to his / her own conclusion by applying the legislative enactments and judicial pronouncements to ...

June 21, 2017 2352 Views 1 comment Print

No bar Under OECD to provide document relied to Appellant; Mere showing of document not sufficient

Income Tax : High Court held that to say that the person being prosecuted or proceeded against can only be 'shown' such documents, but not prov...

May 31, 2017 717 Views 0 comment Print

Latest Notifications

SEBI Meeting on Implementation of OECD Principles of Corporate Governance, Spot Price Determination of Commodities etc.

SEBI : PR No. 297/2015 Sixth Meeting of the International Advisory Board of SEBI The Sixth meeting of the International Advisory Board (I...

December 23, 2015 525 Views 0 comment Print

Guidance on Implementation on FATCA and CRS

Income Tax : To combat the problem of offshore tax evasion and avoidance and stashing of unaccounted money abroad requiring cooperation amongst...

August 31, 2015 1717 Views 0 comment Print

Organization for Economic Cooperation and Development (OECD)

August 27, 2022 1257 Views 0 comment Print

Understanding the role of the Organization for Economic Cooperation and Development (OECD) in international taxation and transfer pricing.

It is not at whim or fancy of a Tax authority to decide as to what constitutes beneficial ownership

June 17, 2022 681 Views 0 comment Print

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 satisfied in the present case.

Mutual Agreement Procedures (MAP)

June 16, 2022 6981 Views 2 comments Print

Learn about Mutual Agreement Procedures (MAP) and how they help resolve double taxation and non-taxation issues in cross-border transactions.

New Taxation Developments- United Arab Emirates (UAE)

May 24, 2022 4332 Views 1 comment Print

Exploring the new taxation developments in the UAE: learn about the introduction of corporate tax and its impact on the country’s tax-free economy.

Anatomy of Intangible Transfer Pricing Scheme, With A Focus on Corporate Restructurings

May 18, 2022 1686 Views 0 comment Print

Amidst the OECD’s inclusionary efforts, many issues remain unresolved, particularly when it comes to the transfer of intangibles for the specific purpose of business restructurings. Cross-border transfers of intangibles are frequently made with the final goal of changing corporate structures, such as when a company is entirely comprised of this type of assets (IP company).

Critical Analysis on Mandatory Binding Arbitration in India

May 18, 2022 2334 Views 0 comment Print

Explore the issue of mandatory binding arbitration in India and its critical analysis. Learn about the impact on double taxation avoidance agreements and dispute resolution mechanisms.

OECD BEPS Action Plan 2- Rise of Substantialism

January 28, 2022 2271 Views 0 comment Print

In this era of accelerated globalisation, cross border tax interactions have been high on the political agenda of the multinational entities (‘MNE’). Globalisation, inter-alia brings in inter-country mobility of corporate presence, employees, technology, intellectual property, know-how etc. With increased cross border movement of such elements comes tax controversies, most controversial one being cross border profit […]

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

January 20, 2022 2862 Views 0 comment Print

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 details about tax evaders who hide money in offshore places/tax havens which fall under banking secrecy jurisdictions such as countries like Cayman Islands, and Argentina etc. British Virgin Islands, Bermuda, Bahamas, Cayman Islands, and Argentina etc.

Role of Working Capital Adjustments in Transfer Pricing

October 31, 2021 9180 Views 0 comment Print

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 (internal or external comparables) […]

International Tax Deal For Digital Age, Finally

October 30, 2021 2028 Views 0 comment Print

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 […]