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 : Learn how DTAAs affect capital gains tax on Indian mutual funds for non-residents. Judicial precedents clarify that gains are ofte...
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...
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.
Transfer pricing refer to the strategies which determine the trading price for goods or services between the related parties which is defined under Section 2(76) of Companies act 2016 and covered in AS 18 and IND AS 24. Transfer pricing empowers changes in pricing. Transactions under Transfer pricing between related entities in different countries is one of the most important and complex issue of taxation which global companies face.
As the world moves increasingly towards economic integration and globalization there is a lot of cross border trade, investment and business which will only increase as more and more developing and least developed countries open up their borders for more business with the international community.
