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 for activities with real substance, intended to accommodate abandonment of tax-sparing provisions may not be sufficient, as illustratively explained in the write-up.
https://www.southcentre.int/wp-content/uploads/2022/01/Tax-PB-22.pdf
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 GloBE Rules under Pillar Two, it is expected that a common st
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 Law Tribunal (NCLT), which is the Adjudicating Authority (AA),
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 Rainbow Papers Ltd , where the Apex Court's verdict leads to an
