The Two-Pillar Solution to stimulate APAs
In the backdrop of the recent releases of Public Consultation Documents by the OECD on Amount B under Pillar One and Tax Certainty for...
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Apex Court Verdict in Vidarbha Industries - Adding to IBC Woes?
The Hon’ble Supreme Court (SC) in the case of Vidarbha Power Industries Pvt Ltd has held that under section 7(5)(a), the National Company...
Why are Lord Ram and Lord Krishna thinking differently?
The recent verdicts under the IBC of different benches of the Supreme Court are at variance with each other, as observed in the case of...
Pillar Two must Align with India's FDI Vision
Foreign Direct Investment (FDI) is one of the compelling needs of a developing economy. One of its key achievements of Hon’ble Narendra...
Insolvency Professionals – An IBC Pillar Whose Systemic Support Needs Upgradation
Insolvency Professionals form a crucial pillar on which the entire edifice of the insolvency resolution process rests. During CIRP, the...
Combat COVID-19 impact through APAs
Can APAs be applied as a mechanism to address tax uncertainties in times of COVID-19? Of course, yes! The past couple of years have...
MAP delayed is MAP denied
MAP guidance dated 7 August 2020 states that a taxpayer can request for assistance under MAP regardless of the remedies provided under...
India's Status under the MLI: A Statistical Summary
The din caused by the prevailing Pillar One and Pillar Two discussions has almost pushed the important anti-BEPS measures introduced...
Interaction of IIR with CFC and Tax-sparing Provisions
Adoption of IIR (which is an extension of CFC rules) under Pillar Two is going to create conflict with the tax-sparing rules. Carve outs...
IBC and its Impact on the Indian Economy - An Overview
IBC is perhaps one of the most critical legislations introduced in the preceding decade impacting the ‘ease of doing business in India’...
Combatting Tax Treaty Abuse: Tools available under the BEPS Multilateral Instrument
South Centre, Geneva has published my article titled ‘Combatting Tax Treaty Abuse: Tools available under the BEPS Multilateral...
Tax Sovereignty Principle and Its Peaceful Coexistence with Article 12B of the UN MTC
South Centre, Geneva has recently published my above titled article as a Tax Cooperation Policy Brief. The write-up analyses the...
It’s time for the UN to assert itself on tax matters
The UN has inserted a new Article 12B in the UN Model for taxation of automated digital services, whereas, the OECD is at the brink of...
Time is ripe for DTAA between India and Maldives
Within the past twelve-month period, the Maldives tax authority has published transfer pricing regulations, country-by-country reporting...
Growth in APA club
It’s a delight to note that the APA club is slowly expanding as the Third Amendment to the Tax Administration Regulation granted the...
Russia Begins Process of Withdrawing from the Dutch Tax Treaty
Russian Government has commenced formal process to terminate its treaty with the Netherlands. (Source: https://news.bloombergtax.com/payr...
Update on MLI – Impact of ratification on Malaysia’s treaty network
1. Malaysia signed the MLI on 24 January, 2018 and deposited its instrument of ratification on 18 February, 2021, as a result of which,...
Update on MLI – Impact of ratification on Croatia’s treaty network
1. Croatia signed the MLI on 07 June 2017 and deposited its instrument of ratification on 18 February 2021, as a result of which, MLI...
Update on MLI – As on 20 February, 2021
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”) is an outcome of...
List of India's DTAAs signed and entered into force as on 18 February 2021.
I have often encountered confusion amongst the tax fraternity in India over the number of DTAAs signed by India (and which have entered...
Articles & Views: Blog2
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