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...
In the backdrop of the recent releases of Public Consultation Documents by the OECD on Amount B under Pillar One and Tax Certainty for...
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...
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...
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 form a crucial pillar on which the entire edifice of the insolvency resolution process rests. During CIRP, the...
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 guidance dated 7 August 2020 states that a taxpayer can request for assistance under MAP regardless of the remedies provided under...
The din caused by the prevailing Pillar One and Pillar Two discussions has almost pushed the important anti-BEPS measures introduced...
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 is perhaps one of the most critical legislations introduced in the preceding decade impacting the ‘ease of doing business in India’...
South Centre, Geneva has published my article titled ‘Combatting Tax Treaty Abuse: Tools available under the BEPS Multilateral...
South Centre, Geneva has recently published my above titled article as a Tax Cooperation Policy Brief. The write-up analyses the...
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...
Within the past twelve-month period, the Maldives tax authority has published transfer pricing regulations, country-by-country reporting...
It’s a delight to note that the APA club is slowly expanding as the Third Amendment to the Tax Administration Regulation granted the...
Russian Government has commenced formal process to terminate its treaty with the Netherlands. (Source: https://news.bloombergtax.com/payr...
1. Malaysia signed the MLI on 24 January, 2018 and deposited its instrument of ratification on 18 February, 2021, as a result of which,...
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...
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”) is an outcome of...
I have often encountered confusion amongst the tax fraternity in India over the number of DTAAs signed by India (and which have entered...