OECD articles

Amendment in MAP Rules -A taxpayer’s tool reinvented

Mutual Agreements Procedure (MAP) is a model or mechanism available to taxpayers to resolve disputes that have arisen due to double taxation. When two countries enter into an agreement to avoid double taxation, it gives a clear pathway to the concerned authorities under MAP in those particular jurisdictions....

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Posted Under: Income Tax |

‘Make Available Clause’ & ‘Most Favoured Nation’ Clause & Interplay

The issue of interpretation of agreements for avoidance for double taxation [AADT / DTAA / tax treaty] has always been ongoing. More particularly when it involves importing the meaning of any expressions from the interpretation adopted for any other tax treaty. India has signed tax treaties with various countries out of which certain DTAA...

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Posted Under: Income Tax |

Interlinkage between Valuation and Transfer Pricing

We see that whenever there is any TP litigation in relation to valuation of assets or shares, following are the issues that are raised by the IRD while evaluating the valuation report:...

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Posted Under: Income Tax |

Pioneers in taxation of digitally growing economy

With the expansion of information and communication technology influencing the modes and scales of supply and procurement of goods and services exponentially, the digital economy has enabled conducting of businesses without regard to national boundaries and physical presence.  The same has also resulted in novel issues in the tax regime ...

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Posted Under: Income Tax |

BEPS -Overview of OECD’S International Tax Structure

The Policy of Liberalization, Privatization and globalization has developed economy globally. The Foreign Direct Investment received by the countries because of above-mentioned policies has helped them in developing and boosting their economy.2 One of the key-policy i.e. globalization has integrated various economies into one and helped b...

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Posted Under: Income Tax |

India’s Position on Multilateral Instrument

One of the big challenges which the Organisation of Economic and Cooperation Development (OECD) face is the shifting of the base of the profit by various global entities. By using the treaty benefits such entities can either save or avoid paying taxes....

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Posted Under: Income Tax |

OECD develops database to provide insights on Global profiles of MNEs

OECD develops database to provide insights on Global profiles of Multinational Enterprises (MNEs) 1. Background Multinational Enterprises (MNEs) have been at the forefront of changes in the global economy over the last few decades, as trade and investment barriers have been removed and transportation and communication costs have declined....

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Posted Under: Income Tax |

Country By Country Reporting

The Finance Act, 2016 introduced provisions relating to Country by Country Report (CbCR) and Master File pursuant to adoption of OECD’s BEPS Action Plan-13 in India. On 31st October 2017, CBDT released the Final Rules with respect to maintenance and furnishing of Master File and CbCR. Summary of Final Forms and Rules for Master-File app...

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Posted Under: Income Tax |

Taxing Royalty Payments in Digital economy

In our Transfer Pricing world, the OECD has duly acknowledged the fact that the business environment has evolved due to change in technology and digitalization. The efforts of OECD to walk hand in hand with the ongoing evolution of technology is visible from its work in Action 1 – Digitalisation, Business Models and Value Creation, wher...

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Posted Under: Income Tax |

Fundamental of Base Erosion and Profit Shifting

Base Erosion and Profit Shifting (BEPS) has emerged as one of the most important challenges for governments all over the world. The Liberalization, Privatization and Globalization (LPG) has resulted; Free movement of Capital and Labour; Shift of manufacturing base from high cost to lower cost locations; Gradual removal of the trade barri...

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Posted Under: Income Tax |

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