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...
What is happening today? Today, under the mandate of the G20, the OECD Inclusive Framework has just presented a new stage of the BEPS 2.0 initiative, to address the challenges of taxing multinational corporations in the digital era. Previous attempts at tax reform have only tried to plug the holes in our international tax system […]
In a new report, ICRICT evaluates the forthcoming OECD solution to tax multinationals and calls for a fair and comprehensive reform that would tax multinationals as single firms, using formulary apportionment based on objective factors, together with a minimum effective corporate tax rate of 25%. A significant challenge to resource availability – and to the […]
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 has released the synthesised text for India-UAE tax treaty. It represents their shared understanding of the modifications made to the Agreement by MLI.
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.
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
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 […]
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.
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. […]
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 […]
