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Digital Taxation: Strategies and Implications for Global Economies

Income Tax : Delve into the complexities of digital taxation, exploring its evolution, significance, and global responses. Learn about fair ta...

April 30, 2024 711 Views 0 comment Print

Alignment of Section 286 of Income Tax Act with OECD BEPS Action Plan 13

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...

April 26, 2024 510 Views 0 comment Print

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 1212 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 705 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 351 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 687 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 471 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 438 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 360 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 657 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 699 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 2403 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 738 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 534 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 1831 Views 0 comment Print


CBDT releases MLI synthesised text for India- Serbia and Montenegro tax treaties

September 11, 2019 981 Views 0 comment Print

CBDT has released the synthesised text for India- Serbia and Montenegro 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 AND THE CONVENTION BETWEEN THE GOVERNMENT OF THE REPUBLIC […]

CBDT releases MLI synthesised text for India- UAE tax treaties

September 3, 2019 2934 Views 0 comment Print

CBDT has released the synthesised text for India-UAE tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI.

MLI synthesised text for India- Japan tax treaties

August 27, 2019 2256 Views 0 comment Print

Synthesised text of MLI and Convention between Government of Japan and Government of Republic of India for Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income.

Taxing Royalty Payments in Digital economy

August 27, 2019 1746 Views 0 comment Print

In our Transfer Pricing world, the OECD has duly acknowledged the fact that the business environment has evolved due to change in technology and digitalization. The efforts of OECD to walk hand in hand with the ongoing evolution of technology is visible from its work in Action 1 – Digitalisation, Business Models and Value Creation, where it is trying to justify its underlying principle need to align transfer pricing outcome with value creation

Fundamental of Base Erosion and Profit Shifting

July 11, 2019 3069 Views 0 comment Print

Base Erosion and Profit Shifting (BEPS) has emerged as one of the most important challenges for governments all over the world. The Liberalization, Privatization and Globalization (LPG) has resulted; Free movement of Capital and Labour; Shift of manufacturing base from high cost to lower cost locations; Gradual removal of the trade barriers, and Rise of digital […]

Solving The Dilemma of Dual Residence

June 18, 2019 2583 Views 0 comment Print

This paper aims at analysing the tie-breaker test in determining residence in the OECD as prescribed under Article 4(3) and how it is evolved. It analyses the 2017 update to the OECD which prescribes the Mutual Agreement Procedure (MAP). The paper finally provides a method of properly implementing MAP and how it can be effectively done so through arbitration by choosing the correct method.

Income Tax Updates for May 2019

June 11, 2019 17136 Views 2 comments Print

NEWS DIRECT TAX 1. CBDT notifies TIEA between India-Marshall Islands. [Notification no 40/2019/F.No. 503/1/2018-FT & TR– IV] 2. Form 15H can be furnished if no tax payable on income after sec. 87A rebate. [Notification No. 41/2019/F. No. 370142/5/2019-TPL] 3. CBDT releases draft notification proposing new audit report Form for Trust/Institution. [NOTIFICATION F.NO. 370142/6/2019-TPL, DATED 21-5-2019] 4. […]

Curbing the Intangible Shenanigan – Hard to value Intangibles

January 5, 2019 1125 Views 2 comments Print

Anurag Agrawal Introduction Over several decades and in step with the globalisation of the economy, intra group transactions have grown exponentially world-wide especially related to intangible assets. The word “intangible asset” is intended to address something which is not a physical asset or a financial asset, which is capable of being owned or controlled for […]

Thin Capitalization – Section 94B

November 8, 2018 27786 Views 2 comments Print

India has time and again shown its commitment to BEPS initiative of the OECD and introduced several reforms in domestic tax legislation to plug loopholes, strengthen information sharing between the contracting states and prevent double non-taxation. In line with its commitment, vide Finance Act 2017; the government has introduced measures to curb thin capitalization in […]

Overview of Multilateral Instrument (MLI)

August 23, 2018 25881 Views 0 comment Print

‘Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting’ (MLI for short) is the official title of the multilateral treaty framework that aims to prevent BEPS. Base erosion and profit shifting (BEPS) refers to artificially shifting profits to low or no-tax locations where there is little or no economic […]

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