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Latest Articles


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


Thin Capitalisation introduced under Income-tax with FAQs

April 15, 2018 11523 Views 1 comment Print

In order to curb structuring by the multinational group Companies having their presence through subsidiaries/ associate companies or permanent establishments in India, the Finance Act 2017 introduced a new section 94B under the Income-tax Act, 1961 (the Act), in line with the recommendations of OECD BEPS Action Plan 4

Country by Country Reporting (CbC Reporting) – India’s Step Forward to OECD’s BEPS Action Plans

February 7, 2018 13650 Views 0 comment Print

The OECD report on Action Plan 13 of BEPS Action plan provides for re-examination of transfer pricing documentation. It also provides for a template for country-by-country reporting of income, earnings, taxes paid and certain measure of economic activity.

Domestic Dependent Agency Rules – Parity with MLI standards

February 4, 2018 10305 Views 0 comment Print

The concept of Business connection under the domestic tax laws is akin to concept of PE in international parlance. The term ‘business connection’ includes activities carried on by non-resident through its dependent agents. Presently, a person acting on the behalf of the non-resident by negotiating and concluding contracts, maintaining stock of goods in India or habitually securing orders in India mainly or wholly for the non-resident would constitute its dependant agent in India.

Scope of “business connection” with modified PE Rule as per MLI

February 3, 2018 2808 Views 0 comment Print

The OECD under BEPS Action Plan 7 reviewed the definition of ‘PE’ with a view to preventing avoidance of payment of tax by circumventing the existing PE definition by way of commissionaire arrangements or fragmentation of business activities.

Transfer Pricing Documentation and Reporting

January 27, 2018 31653 Views 1 comment Print

This article analyses the provisions notified to give effect to the OECD recommendations on three tiered Transfer Pricing documentation, regarding the entities to which the provisions will apply.

Transfer pricing guidelines– Global/Indian scene: Latest income tax obligations of entities

January 20, 2018 2340 Views 0 comment Print

The following article has been written to explain the salient features of the reporting requirements enforced on corporations in India/abroad which are said to assist tax authorities around the world to use transfer pricing audit to get the tax due to their countries from corporations who seemed to have found various ways to avoid the tax owed by them.

Acceptance of Transfer Pricing MAP and bilateral APA – Reg.

November 27, 2017 1065 Views 0 comment Print

Clarification of India’s position on the acceptance of MAP and bilateral APA in cases of countries where Article 9(2) of OECD Model Tax Commentary is absent

Fighting Tax Crime: The Ten Global Principles

November 14, 2017 1050 Views 0 comment Print

This report sets out the 10 essential principles for effectively fighting tax crimes. It covers the legal, institutional, administrative, and operational aspects necessary for putting in place an efficient system for fighting tax crimes and other financial crimes. It draws on the insights and experience of jurisdictions around the world. The purpose is to allow […]

Effective Inter-Agency Co-Operation in Fighting Tax Crimes and Other Financial Crimes (Third Edition)

November 14, 2017 657 Views 0 comment Print

This report describes the current position in 51 countries as to the law and practice for domestic inter-agency co-operation in fighting tax crimes and other financial crimes including, for the first time, co-operation with authorities responsible for the investigation and prosecution of corruption. It identifies successful practices based on countries’ experiences of inter-agency co-operation in […]

Tax Inspectors Without Borders – Bolstering domestic revenue collection through improved tax audit capacities

November 14, 2017 1506 Views 0 comment Print

International tax experts gathered today at the OECD in Paris to share experiences and identify best practices in the implementation of Tax Inspectors Without Borders (TIWB) programmes.

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