Income Tax : This blog will examine the causes of tax evasion in India, the effects it has on society, and possible remedies to guarantee a mor...
Income Tax : Explore the impact of OECD Two-Pillar tax rules on Indian MNEs. Key changes include taxing profits where value is created and a gl...
Income Tax : Explore the complexities and solutions of taxing the digital economy, including BEPS Action-1, Pillar-1 reforms, and the challenge...
Income Tax : Explore India's taxation laws on international e-commerce transactions, including equalisation levy, withholding tax, and implicat...
Income Tax : Delve into the complexities of digital taxation, exploring its evolution, significance, and global responses. Learn about fair ta...
Income Tax : Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 bi...
Income Tax : Tax Inspectors Without Borders (TIWB), a joint initiative of the United Nations Development Programme (UNDP) and the Organisation ...
Income Tax : Majority of the members OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting(including India)adoptedyesterday ahigh-le...
Income Tax : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...
Income Tax : CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications ...
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...
Income Tax : A reader should be able to come to his / her own conclusion by applying the legislative enactments and judicial pronouncements to ...
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...
SEBI : PR No. 297/2015 Sixth Meeting of the International Advisory Board of SEBI The Sixth meeting of the International Advisory Board (I...
Income Tax : To combat the problem of offshore tax evasion and avoidance and stashing of unaccounted money abroad requiring cooperation amongst...
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).
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.
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 […]
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.
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) […]
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 […]
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.
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 years ago.
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 […]
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.
