top of page
Search

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 the GloBE Rules under Pillar Two, it is expected that a common standard would be defined by the OECD for an APA-like mechanism to be adopted in the context of the GloBE Rules. Further, OECD has opined that taxpayers can make use of the mechanisms available to avoid future disputes in relation to the application of Amount B through APAs.


With above stated developments on the anvil arising out of the Two-Pillar Solution having direct impact on APAs, it is clearly visible that the APA regime has immense opportunity for growth.



Taxsutra Article - The Two-Pillar Solution to stimulate APAs
.pdf
Download PDF • 1.19MB

7 views0 comments

Recent Posts

See All

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

Foreign Direct Investment (FDI) is one of the compelling needs of a developing economy. One of its key achievements of Hon’ble Narendra Modi government is that more than 50 percent of the FDI India ha

Post: Blog2_Post
bottom of page