Recently, OECD released an update to the OECD model convention and commentary (“2017 update”). The 2017 update largely consists of amendments agreed upon as part of the BEPS project and follow up work thereon. In addition, it incorporates certain other changes that were released for public comments previously and finalized now. It also contains the … More India’s position on the “2017 OECD update”: Deviating from an international consensus?
Digitalization of the global economy has happened at a tremendous pace and a large scale, permeating almost all areas of society. However, emergence of new business models have made it harder to tax businesses possessing a digitalized value chain. Conventional source allocation rules related to brick and mortar structures are not apt for the digital … More Taxation in digital economy, making way legally
OECD proposes changes to be incorporated in the 2017 update to the OECD Model Tax Treaty The Organisation for Economic Co-operation and Development (OECD) on 11 July 2017 released the draft contents of the update to the OECD Model Tax Convention (the 2017 update). Among a number of other proposals, the 2017 update contains changes … More Developments in International Tax: An update and its impact
Tax treaties are based on a set of common principles designed to eliminate double taxation that may occur in the case of cross-border trade and investments. The current network of bilateral tax treaties dates back to the 1920s and the first Model Tax Convention developed by the League of Nations. The Organisation for Economic Co-operation … More The Multilateral Instrument and the future of bilateral tax treaties
The year 2016 witnessed a rapid movement of the OECD-G20 BEPS project to the implementation phase, leaving a fundamentally changed landscape in its wake. Now that all the key instruments for BEPS implementation have been released by the OECD, countries are legislating and/or providing more clarity on how they will implement BEPS measures so that … More Budget 2017: what international tax may have in store for you!
In 2015, there were exceptional changes in the global tax landscape — Base Erosion and Profit Shifting (BEPS) discussion drafts turned into final recommendations with many jurisdictions already legislating on a unilateral basis in anticipation of final recommendations. Across the globe, new and sometimes highly novel national legislation was released to address BEPS challenges. The … More Budget 2016 – what does it entail from BEPS perspective
Different countries may have different ways in which they choose to set the jurisdiction for tax under the residence principle. However, there is a degree of consensus on the basic principle that there should be a fairly strong economic nexus with that country. Two basic approaches are used in establishing a personal jurisdictional connection for … More Place of Effective Management (POEM): striking the right balance