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Latest Articles

Country-by-Country Reporting (CbCR)

Income Tax : Country-by-Country Reporting (CbCR) is a crucial component of the transfer pricing documentation requirements introduced by the Or...

March 31, 2024 891 Views 0 comment Print

Introduction to Pillar one Amount B in OECD

Income Tax : Discover how the OECD's introduction of Pillar One Amount B in 2024 streamlines transfer pricing for marketing and distribution, e...

March 3, 2024 588 Views 0 comment Print

Evolution of OECD’s concept of Harmful Tax Practices: From 1998 Report to BEPS Action 5 Approach

Income Tax : Explore the evolution of harmful tax practices from the OECD's 1998 report to the BEPS Action 5 approach, focusing on transparency...

February 21, 2024 297 Views 0 comment Print

Navigating Global Maze: India and New Era of Minimum Corporate Taxation

Income Tax : Explore the impact of OECD's Global Minimum Tax Agreement on India's tax landscape. Uncover challenges, opportunities, and India's...

February 2, 2024 396 Views 0 comment Print

BEPS 2.0: Unpacking Pillar One and Pillar Two Proposals

Income Tax : Dive into BEPS 2.0 with an in-depth analysis of Pillar One & Pillar Two proposals, reshaping international tax. Explore the impact...

December 21, 2023 1539 Views 0 comment Print

Latest News

ICRICT Open letter to G20 Heads of State and Government

Income Tax : Eight years ago, you mandated the OECD to address corporate tax avoidance by multinationals, which cost countries at least $240 bi...

October 12, 2021 678 Views 0 comment Print

Seychelles’ Tax Inspectors Without Borders programme launched

Income Tax : Tax Inspectors Without Borders (TIWB), a joint initiative of the United Nations Development Programme (UNDP) and the Organisation ...

October 5, 2021 456 Views 0 comment Print

India joins OECD/G20 Inclusive Framework tax deal

Income Tax : Majority of the members OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting(including India)adoptedyesterday ahigh-le...

July 2, 2021 429 Views 0 comment Print

CBDT releases MLI synthesised text for India-Czechoslovak Socialist Republic tax treaty

Income Tax : CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modif...

March 19, 2020 342 Views 0 comment Print

CBDT releases MLI synthesised text for India-Poland tax treaty

Income Tax : CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications ...

March 19, 2020 639 Views 0 comment Print

Latest Judiciary

It is not at whim or fancy of a Tax authority to decide as to what constitutes beneficial ownership

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...

June 17, 2022 681 Views 0 comment Print

ITAT – taking virtual reality a bit too seriously ?

Income Tax : A reader should be able to come to his / her own conclusion by applying the legislative enactments and judicial pronouncements to ...

June 21, 2017 2352 Views 1 comment Print

No bar Under OECD to provide document relied to Appellant; Mere showing of document not sufficient

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...

May 31, 2017 717 Views 0 comment Print

Latest Notifications

SEBI Meeting on Implementation of OECD Principles of Corporate Governance, Spot Price Determination of Commodities etc.

SEBI : PR No. 297/2015 Sixth Meeting of the International Advisory Board of SEBI The Sixth meeting of the International Advisory Board (I...

December 23, 2015 525 Views 0 comment Print

Guidance on Implementation on FATCA and CRS

Income Tax : To combat the problem of offshore tax evasion and avoidance and stashing of unaccounted money abroad requiring cooperation amongst...

August 31, 2015 1717 Views 0 comment Print

OECD’s Unified Approach on Pillar One to Address the Challenges Arising from Digitalization of Economy: A Critical Analysis

August 8, 2020 2862 Views 0 comment Print

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.

Mutual Agreement Procedure (MAP)

August 8, 2020 14250 Views 0 comment Print

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 […]

Are Tax Havens good for Developing Economies?

August 5, 2020 7452 Views 2 comments Print

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 […]

OECD’s Multilateral Instrument and its impact on BEPS

July 30, 2020 1842 Views 6 comments Print

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 […]

Using the Most Favoured Nation (‘MFN’) clause for better cash flows

July 1, 2020 8511 Views 2 comments Print

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 […]

OECD Project to Tax Digital Economy: At the Brink of Collapse?

June 27, 2020 1161 Views 0 comment Print

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.

CBDT Clarification on Tax Residency – A Scope for New Interpretation

June 17, 2020 2805 Views 0 comment Print

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 […]

Amendment in MAP Rules -A taxpayer’s tool reinvented

June 17, 2020 1032 Views 0 comment Print

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.

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

June 8, 2020 47415 Views 3 comments Print

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’s (viz., […]

Interlinkage between Valuation and Transfer Pricing

June 1, 2020 5883 Views 0 comment Print

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: