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...
In this article you will find detailed analysis of certain terms and issues which either OECD or certain other countries have clarified. Notification in respect of BEPS Action plan 13 is expected shortly from CBDT.
CbCR (Country by Country Report) is one of the recent amendment which has created a lot of hue and cry in the industry, hence here in this article the author will provide the basic concepts related to CbC reporting for all the Chartered Accountants.
This article provides a comprehensive summary of the efforts undertaken by OECD in addressing the issues relating to the Tax Challenges Arising from the Digitalisation of the Economy. The article then discusses the intricacies of the proposed Unified Approach issued by OECD Secretariat and endorsed by the OECD Inclusive Framework on Base Erosion and Profit Shifting Project.
The mutual agreement procedure is a well-established means through which tax administrations consult to resolve disputes regarding the application of double tax conventions. This procedure, described and authorized by Article 25 of the OECD Model Tax Convention, can be used to eliminate double taxation that could arise from a transfer pricing adjustment. Article 25 sets […]
A tax haven is a country where taxes are levied at extremely low rates. One country’s tax laws and rules can have an effect on other countries and their economies. Most multinationals operating in developing countries use tax havens. These tax havens often prove to be a way for multinational companies to avoid taxes. More […]
One of the biggest problems in today’s international tax regime is the loss of billions of global corporate income tax revenues through the use of legal tax avoidance strategies. ‘Base Erosion and Profit Shifting (BEPS) is a phrase commonly used to refer to tax avoidance strategies that taxpayers use to shift their profits from high […]
Everyone is conversant with the proverb ‘Old wine in new bottles‘. On similar lines, the Finance Act, 2020 shifts the incidence of taxation of dividends in the hands of shareholders by abolishing the DDT regime. Under the new regime (effective 1 April 2020), the dividends earned by foreign shareholders are usually subject to a tax […]
Last two years have witnessed a large-scale collaborative effort by the international community, under the umbrella of the OECD, towards finding a consensus-based solution for the problem of taxation within the digitalized economy.
As per the OECD Convention Model, 2017 the term resident of a country means any person who, under his native country is liable to tax therein by reason of his domicile, residence or place of effective management. Due to COVID-19, if an individual is present in a jurisdiction for a considerable amount of time, it […]
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.
