Determination of tax residence based on the Place of Effective Management (PoEM) has been in force in India since April 2016, with guidance and clarification from tax authorities issued in January 2017. The guidance has shed more light on cases that the Government intends to cover within the ambit of the PoEM regulations. However, as … More Place of Effective Management – Decoding UK’s Development Securities decision in the Indian context
Formulating anti-BEPS (Base Erosion and Profit Shifting) measures for cases where companies were deemed to not have a Permanent Establishment (PE) despite substantial business activity, was a key priority for the Organisation for Economic Cooperation and Development (OECD) in its BEPS project. Recommendations and outcomes from the OECD Action Plan 7 of the BEPS project, … More The evolution and rethink of the Permanent Establishment concept as a consequence of BEPS
The NDA Government’s second Union Budget is coming at rather interesting crossroads, from the point of view of international taxation. On one hand, there is persistent reinstatement of efforts toward having a non-adversarial tax regime; while on the other, legislative enforcement of the OECD Base Erosion and Profit Shifting (BEPS) recommendations, which have changed the … More Union Budget 2016-17: decoding the Government’s stand on cross-border taxes
5 October 2015 was a red-letter day for the global tax community. The OECD released final reports on all 15 Action Plans of the Base Erosion and Profit Shifting (BEPS) project, which was undertaken at the behest of the G20. There was tremendous anticipation of these reports due to the amount of global attention and … More BEPS and the Indian outbound investor: are we ready for CFC Rules?