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...
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., […]
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:
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 regarding taxability of revenue from […]
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 big Multi-National Companies to expand and diversify their business.3 […]
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.
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. In a world of global value […]
CBDT has released the synthesised text for India-Slovak Republic tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SLOVAK REPUBLIC AGREEMENT FOR AVOIDANCE OF DOUBLE TAXATION AND PREVENTION OF FISCAL EVASION WITH – SLOVAK REPUBLIC Whereas a Agreement between the Government of the Republic of India and the Government of the Czechoslovak Socialist […]
CBDT has released the synthesised text for India-Poland tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MLI AND THE CONVENTION BETWEEN THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE REPUBLIC OF POLAND FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE […]
CBDT has released the synthesised text for India-Australia tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. AUSTRALIA SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAXT REATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF […]
CBDT has released the synthesised text for India-Singapore tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI. SYNTHESISED TEXT OF THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING (MLI) AND THE AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA […]
