Income Tax : The article explains how multinational digital companies generate substantial revenue from Indian users while shifting profits to ...
Income Tax : The article explains how the coexistence of GloBE and GILTI leads to different tax outcomes for similarly structured multinational...
Income Tax : The Supreme Court's ruling on Permanent Establishment (PE) expands taxability for MNEs, holding that "effective control and contin...
Corporate Law : Global tax system is struggling with digital economy's value creation. OECD's Pillars 1 & 2 introduce new taxing rights and a 15% ...
Income Tax : An overview of the compliance challenges Indian MNEs and tax authorities face due to OECD Pillars 1 and 2, covering profit allocat...
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...
Company Law : The MCA amended AS 22 to incorporate provisions related to OECD Pillar Two global minimum tax rules. The amendment exempts compani...
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...
Understand what qualifies as ‘stewardship activities’ for taxation in India with the Supreme Court’s single-entity approach. Taxes on stewardship activities, Morgan Stanley & Co v India judgement explained
OECD/G20 Inclusive Framework (IF) on BEPS released technical guidance to assist governments with implementation of the GMT, which will ensure Multi-National Entities (MNEs) will be subject to a 15% effective minimum tax rate.
Stay updated with the latest OECD Transfer Pricing Guidelines for 2022. Learn how these guidelines tackle tax avoidance and promote transparency in international tax rules.
Dive into the evolution of taxation for MNEs with Pillar 2 – Global Minimum Tax. Understand the mechanics, implications, and exceptions of this groundbreaking framework to stay informed in the changing landscape of global taxation.
Explore the recent introduction of Federal corporate tax in the UAE, marking a significant change as the country moves towards taxing income. Learn about the applicability of corporate tax, rates for different income brackets, exclusions, exemptions, and filing requirements. Understand the impact on businesses and individuals as UAE undergoes this taxation shift effective from June 2023.
Understanding the role of the Organization for Economic Cooperation and Development (OECD) in international taxation and transfer pricing.
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.
Learn about Mutual Agreement Procedures (MAP) and how they help resolve double taxation and non-taxation issues in cross-border transactions.
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.
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).
