Income Tax : Delve into the complexities of digital taxation, exploring its evolution, significance, and global responses. Learn about fair ta...
Income Tax : Explore the alignment of Section 286 of the Income Tax Act 1961 with OECD BEPS Action Plan 13, emphasizing Country-by-Country Repo...
Income Tax : Country-by-Country Reporting (CbCR) is a crucial component of the transfer pricing documentation requirements introduced by the Or...
Income Tax : Discover how the OECD's introduction of Pillar One Amount B in 2024 streamlines transfer pricing for marketing and distribution, e...
Income Tax : Explore the evolution of harmful tax practices from the OECD's 1998 report to the BEPS Action 5 approach, focusing on transparency...
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...
Majority of the members OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting(including India)adoptedyesterday ahigh-level statement containing an outline of a consensus solution to address the tax challenges arising from the digitalisation of the economy.
Due Date for furnishing Statement under ‘Equalisation Levy’ (EL) for FY 2020-21 is 30.06.2021 || Compilation of Complete Provisions For Your Easy Understanding A. Brief Background The Organisation for Economic Co-operation and Development (OECD) through the Base Erosion and Profit Shifting (BEPS) project under Action Plan 1 recommended a final withholding tax on certain payments […]
Organization for Economic Cooperation and Development (OECD) and the (G20) countries have launched an initiative known as base erosion and profit shifting (BEPS), which consists mostly of tax avoidance methods. These techniques primarily aim to fill in and make accommodations for tax policy loopholes, which aid in leveraging such gaps in tax regulations to deceptively shift earnings to low or no-tax nations. A business is often funded (or capitalized) through a combination of debt and equity.
The taxation of the digital economy was first on the Organization for Economic Co-operation and Development (OECD) list of 15 Base Erosion and Profit Shifting (BEPS) Action items. BEPS Action Plan 1 was announced in 2013 in which it had partially addressed the challenges that would be faced by the digital economy.
There is a great need and importance of introducing CFC i.e. controlled foreign corporation legislation in Indian tax law, as it is one of the biggest measures to avoid payment of income tax in India by the resident persons of India. In the current scenario, there are no such provisions existing in income tax act, […]
There is a great need and importance of introducing CFC i.e. controlled foreign corporation legislation in Indian tax law, as it is one of the biggest measures to avoid payment of income tax in India by the resident persons of India. In the current scenario, there are no such provisions existing in income tax act, […]
With the incessant global growth, the relevance of Permanent Establishment (PE) in international taxation has become paramount. In simpler terms, the expression ‘Permanent Establishment’ means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
In this dynamic era, the brick and mortar business models are turning digital and Multi-National Companies (MNCs) are effectively operating out of various jurisdictions without having a physical presence. From a taxation perspective, it is way more challenging when the value creation, income generation and the adjoining taxability cut across various countries. The Organization for […]
The global tax landscape is constantly evolving to keep pace with ever-changing business models and structures. Introduction of the Base Erosion and Profit Shifting (BEPS) project by OECD/G-20 in the year 2016 was one such significant international stepsince the advent of bilateral tax treaties, wherein more than 100 countries collaborated to block tax avoidance strategies that exploit gaps and mismatches in tax rules across jurisdictions.
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 laws underprivileged (deprived) either/both of treaty partners for having access […]
