Developing Countries should adopt Article 12B of the UN Model as their own Pillar
It is often said that one should build a house on one's own pillars. In order to adopt a treaty based solution to tax the digital...
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Kuldeep Sharma
Dec 4, 20231 min read
Should Developing Countries Go Ahead with Amount A MLC?
Many thanks to Taxsutra for publishing my article. Amount A is a complex set of rules and may not yield enough revenues for the...
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Kuldeep Sharma
Dec 4, 20231 min read
UN STTR Better Option over OECD STTR for Developing Countries
The OECD has released rules for a new MLI that has been developed in order to facilitate implementation of STTR in existing tax treaties...
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Kuldeep Sharma
Dec 4, 20231 min read
UN Secretary-General Report on International Tax Cooperation - What Lies Ahead?
The UN Secretary-General has presented the advance unedited version of the report on 8 August '23 in response to General Assembly...
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Kuldeep Sharma
Dec 4, 20231 min read
United Nations Intergovernmental Process is meant for developing countries
Many thanks to South Centre, Geneva for publishing an Article on the United Nations Intergovernmental Process that envisions the Global...
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Kuldeep Sharma
Dec 4, 20231 min read
Analyzing IBC Tweaks Proposed by MCA
Heartiest gratitude to Taxsutra and LawStreetIndia for publishing an article which encapsulates the proposed amendments dated 28 January...
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Kuldeep Sharma
Jan 2, 20231 min read
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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Kuldeep Sharma
Dec 7, 20221 min read
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...
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Kuldeep Sharma
Sep 14, 20221 min read
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...
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Kuldeep Sharma
Jun 15, 20221 min read
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...
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Kuldeep Sharma
May 24, 20221 min read
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...
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Kuldeep Sharma
Mar 29, 20221 min read
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...
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Kuldeep Sharma
Mar 25, 20221 min read
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...
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Kuldeep Sharma
Feb 15, 20221 min read
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...
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Kuldeep Sharma
Jan 12, 20221 min read
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...
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Kuldeep Sharma
Dec 10, 20211 min read
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’...
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Kuldeep Sharma
Sep 15, 20212 min read
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...
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Kuldeep Sharma
Jun 17, 20211 min read
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...
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Kuldeep Sharma
May 14, 20212 min read
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...
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Kuldeep Sharma
May 14, 20211 min read
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...
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