OECD articles

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 |

CBCR: Why Such Reporting, By Whom, When, What Are the Difficulties and Benefits

CbCR (Country by Country Report) is one of the recent amendment which has created a lot of hue and cry in the industry, hence here in this article the author will provide the basic concepts related to CbC reporting for all the Chartered Accountants. ...

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Posted Under: Income Tax |

OECD’s Unified Approach on Pillar One to Address the Challenges Arising from Digitalization of Economy: A Critical Analysis

This article provides a comprehensive summary of the efforts undertaken by OECD in addressing the issues relating to the Tax Challenges Arising from the Digitalisation of the Economy. The article then discusses the intricacies of the proposed Unified Approach issued by OECD Secretariat and endorsed by the OECD Inclusive Framework on Base ...

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Posted Under: Income Tax |

Mutual Agreement Procedure (MAP)

The mutual agreement procedure is a well-established means through which tax administrations consult to resolve disputes regarding the application of double tax conventions. This procedure, described and authorized by Article 25 of the OECD Model Tax Convention, can be used to eliminate double taxation that could arise from a transfer pri...

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Posted Under: Income Tax |

Are Tax Havens good for Developing Economies?

A tax haven is a country where taxes are levied at extremely low rates. One country’s tax laws and rules can have an effect on other countries and their economies. Most multinationals operating in developing countries use tax havens. These tax havens often prove to be a way for multinational companies to avoid taxes. More […]...

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Posted Under: Income Tax |

OECD’s Multilateral Instrument and its impact on BEPS

One of the biggest problems in today’s international tax regime is the loss of billions of global corporate income tax revenues through the use of legal tax avoidance strategies. ‘Base Erosion and Profit Shifting (BEPS) is a phrase commonly used to refer to tax avoidance strategies that taxpayers use to shift their profits from hi...

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Posted Under: Income Tax |

Using the Most Favoured Nation (‘MFN’) clause for better cash flows

Everyone is conversant with the proverb ‘Old wine in new bottles‘.  On similar lines, the Finance Act, 2020 shifts the incidence of taxation of dividends in the hands of shareholders by abolishing the DDT regime.  Under the new regime (effective 1 April 2020), the dividends earned by foreign shareholders are usually subject ...

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Posted Under: Income Tax |

OECD Project to Tax Digital Economy: At the Brink of Collapse?

Last two years have witnessed a large-scale collaborative effort by the international community, under the umbrella of the OECD, towards finding a consensus-based solution for the problem of taxation within the digitalized economy....

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Posted Under: Income Tax |

CBDT Clarification on Tax Residency – A Scope for New Interpretation

As per the OECD Convention Model, 2017 the term resident of a country means any person who, under his native country is liable to tax therein by reason of his domicile, residence or place of effective management. Due to COVID-19, if an individual is present in a jurisdiction for a considerable amount of time, it […]...

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Posted Under: Income Tax |

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